WP No. 24584 of 2026 __________ Page1 of 4 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 09-07-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 24584 of 2026 and W.M.P.Nos.26817 & 26818 of 2026 ACP Business Enterprises Private Limited, (Represented by its Director MR.Bharani), AB 16/28, 5th Street, 6th Main Road, Anna Nagar,Chennai, Tamil Nadu, 600040. ..Petitioner(s) Vs The Assistant Commissioner Amaindakarai Assessment Circle, papjm annex building, 3rd floor no.1, greams road, chennai-06. ..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 Respondent herein in FORM GST DRC 07 with Reference No. ZD331225404859A dated 26.12.2025 along with the detailed order in GSTIN / 33AANCA3545L1ZH / 2021-22 dated 26.12.2025 for the tax period April 2021 March 2022 and quash the same. For Petitioner(s): Mr.Kamalakanth S For Respondent(s): Ms.G.Dhana Madhri, Government Counsel (Tax) ********** https://www.mhc.tn.gov.in/judis WP No. 24584 of 2026 __________ Page2 of 4 ORDER An order dated 26.12.2025 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. On instructions, learned counsel for the petitioner agrees to remit 25% of the disputed tax demand as a condition for remand. An endorsement to that effect has been made on the bundle. 5. Subject to the condition that the petitioner remits 25% of the disputed tax demand 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 25% of the disputed tax demand. https://www.mhc.tn.gov.in/judis WP No. 24584 of 2026 __________ Page3 of 4 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. 09-07-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To The Assistant Commissioner Amaindakarai Assessment Circle, papjm annex building, 3rd floor no.1, greams road, chennai-06. https://www.mhc.tn.gov.in/judis WP No. 24584 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 24584 of 2026 and W.M.P.Nos.26817 & 26818 of 2026 09-07-2026 https://www.mhc.tn.gov.in/judis