WP No. 24174 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. 24174 of 2026 and W.M.P.Nos.26293 & 26294 of 2026 E2643 Marungur Primary Agricultural Coop Credit Society Limited (Represented by its secretary MR.K.Sridhar) E2643, Primary Agriculture Co-Op Credit Society, Marungur, Cuddalore, Tamil Nadu - 607103. ..Petitioner(s) Vs 1. The State Tax Officer panruti rural, cuddalore, Tamilnadu – 607106. 2. The Deputy Commissioner (CT) GST Appeals, Cuddalore, Tamil Nadu - 607 001 ..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 on the files of the 1st Respondent herein in his proceeding in FORM GST DRC 07 with Reference No. ZD331125421475P along with detailed order in GSTIN 33AAAAE4464F1Z3 /2021-22 both dated 24.11.2025 for the tax period APR 2021 - MAR 2022 and quash the same. https://www.mhc.tn.gov.in/judis WP No. 24174 of 2026 __________ Page2 of 4 For Petitioner(s): Mr.B Syed Abdul Wakeel For Respondent(s): Mr.R.Sethu Prabakaran, Government Counsel (Tax) ********* ORDER An order dated 24.11.2025 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 a 10% pre-deposit was made while lodging the appeal. Subject to giving credit thereto, on instructions, learned counsel for the petitioner agrees to remit an additional 15% 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. 24174 of 2026 __________ Page3 of 4 5. Subject to the remittance of an additional 15% of the disputed tax demand 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 the additional 15% by the petitioner. 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 1. The State Tax Officer panruti rural, cuddalore, Tamilnadu – 607106. 2. The Deputy Commissioner (CT) GST Appeals, Cuddalore, Tamil Nadu - 607 001 https://www.mhc.tn.gov.in/judis WP No. 24174 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 24174 of 2026 and W.M.P.Nos.26293 & 26294 of 2026 07-07-2026 https://www.mhc.tn.gov.in/judis