WP No. 24342 of 2026 __________ Page1 of 4 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 07-07-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 24342 of 2026 and W.M.P.Nos.26522 & 26523 of 2026 International Courier Services Represented by its Proprietor David Raj No.16, 3rd Cross Street Selva Ganapathy Nagar Poonamallee ,Chennai 600 056 ..Petitioner(s) Vs The Deputy State Tax Officer II Poonamallee Assessment Circle 4/109, Third Floor, Bangalore Chennai Highway, Varadharajapuram, Nazarathpet, Chennai-600 123 ..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 proceedings of the Respondent in GSTIN 33ALCPD1054E4ZV/ 2021-22, culminating in the Assessment Order dated 16.12.2025, passed under Section 73 of the CGST/TNGST Act, 2017, bearing Reference No.ZD331225242431W, along with the consequential Form GST DRC-07 dated 16.12.2025 and quash all the impugned proceedings as passed https://www.mhc.tn.gov.in/judis WP No. 24342 of 2026 __________ Page2 of 4 contrary to the provisions of the CGST/TNGST Act, 2017, and against the principles of natural justice. For Petitioner(s): Mr.Rajkumar P For Respondent(s): Mr.R.Sethu Prabakaran, Government Counsel (Tax) ********** ORDER An order dated 16.12.2025 is assailed on the ground that the petitioner did not have a reasonable opportunity to contest the tax demand on merits. 2. Mr.R.Sethu Prabakaran, 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 the 10% pre-deposit was made while lodging the appeal. Subject to giving credit thereto, on instructions, he submits that an additional 15% would be remitted as a condition for remand. https://www.mhc.tn.gov.in/judis WP No. 24342 of 2026 __________ Page3 of 4 5. Subject to the remittance of an additional 15% by the petitioner 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 an additional 15% 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. 07-07-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To The Deputy State Tax Officer II Poonamallee Assessment Circle 4/109, Third Floor, Bangalore Chennai Highway, Varadharajapuram, Nazarathpet, Chennai-600 123 https://www.mhc.tn.gov.in/judis WP No. 24342 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 24342 of 2026 and W.M.P.Nos.26522 & 26523 of 2026 07-07-2026 https://www.mhc.tn.gov.in/judis