WP No. 24171 of 2026 __________ Page1 of 4 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 06-07-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 24171 of 2026 and W.M.P.Nos.26289 & 26290 of 2026 Charbhuja Granites Represented by its Authorised Signatory, Ram Swarup, No.222/2A, Seemanoor Road, Near SIDCO Area, Achamangaalam, Krishnagiri, Tamil Nadu - 635 104. ..Petitioner(s) Vs Assistant Commissioner (st) (fac) krishnagiri II Circle, Krishnagiri, Tamilnadu - 635115. ..Respondent(s) PRAYER: Writ Petition filed under Article 226 of The Constitution of India praying for the issuance of a Writ of Certiorari, calling for the records relating to the impugned Order bearing GSTIN 33AAHFC1564A1Z3 (FY 2017-18) dated 03.10.2024 passed by the Respondent and its consequential Assessment Order dated 03.10.2024 having Reference No. ZD331024011429W (FY 2017- 18) issued by the Respondent and quash the same, Direct the respondent to lift the Bank attachment. https://www.mhc.tn.gov.in/judis WP No. 24171 of 2026 __________ Page2 of 4 For Petitioner(s): M/s.Sanskar Samdaria For Respondent(s): Ms.G.Dhana Madhri, Government Counsel (Tax) ********** ORDER An order dated 03.10.2024 is assailed on the ground that the petitioner did not have a reasonable opportunity to contest the tax demand on merits. 2. Ms.G.Dhana Madhri, learned Government Counsel (Tax), accepts notice on behalf of the respondent. 3. On perusal of the impugned order, it is evident that such order was issued without hearing the petitioner. The writ petition has been filed after the period of limitation expired. 4. Learned counsel for the petitioner submits that some recovery was made pursuant to the impugned order. He submits that the petitioner would remit additional amounts so as to remit not less than 50% of the tax demand in the aggregate as a condition for remand. An endorsement to that effect has been made on the bundle. https://www.mhc.tn.gov.in/judis WP No. 24171 of 2026 __________ Page3 of 4 5. Subject to verifying and confirming recoveries made earlier and subject further to the remittance of additional amounts by the petitioner so as to remit not less than 50% of the disputed tax demand in the aggregate within thirty days from the date of receipt of a copy of this order, the impugned order is set aside and the matter is remanded for re-consideration. After providing a reasonable opportunity to the petitioner, a fresh order shall be issued within three months from the date of remittance of not less than 50% in the aggregate by the petitioner. Subject to fulfilment of the above condition, the bank attachment shall stand raised. 6. The writ petition is disposed of on the above terms. Consequently, connected writ miscellaneous petitions are closed. There shall be no order as to costs. 06-07-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To Assistant Commissioner (st) (fac) krishnagiri II Circle, Krishnagiri, Tamilnadu - 635115. https://www.mhc.tn.gov.in/judis WP No. 24171 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 24171 of 2026 and W.M.P.Nos.26289 & 26290 of 2026 06-07-2026 https://www.mhc.tn.gov.in/judis