WP No. 25020 of 2026 __________ Page1 of 4 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 10-07-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 25020 of 2026 and W.M.P.Nos.27295 & 27298 of 2026 Tvl RAS TRADE AGENCY Rep by its Partner Mr. Siraj Mohammed, No. 2/2, Hussain Maracoir Lane Moore Street,Mannady, Chennai 600 001 ..Petitioner(s) Vs The Deputy State Tax Officer II Harbour Assessment Circle, 3rd Floor, Room No 327, No 32, Integrated commercial Tax officers, Complex Elephant Gate Bridge Road, Chennai 600 003 ..Respondent(s) PRAYER: Writ Petition filed under Article 226 of The Constitution of India praying for the issuance of a Writ of Certiorarified Mandamus, calling for the records on the file of the Respondent in the impugned proceedings against the impugned order bearing reference original impugned order vide GSTIN 33AAKFR1071Q1ZU/2021-2022 dated 22.12.2025 with summary order in FORM GST DRC 07 vide ref no. ZD331225347034S dated 22.12.2025 passed by the Respondent, under the provisions of CGST Act, 2017 and quash the same and consequently direct the respondent to pass DE NOVO order. https://www.mhc.tn.gov.in/judis WP No. 25020 of 2026 __________ Page2 of 4 For Petitioner(s): Mr.M. Akbar Basha For Respondent(s): Ms.G.Dhana Madhri, Government Counsel (Tax) *********** ORDER An order dated 22.12.2025 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, https://www.mhc.tn.gov.in/judis WP No. 25020 of 2026 __________ Page3 of 4 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. 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. 10-07-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To The Deputy State Tax Officer II Harbour Assessment Circle, 3rd Floor, Room No 327, No 32, Integrated commercial Tax officers, Complex Elephant Gate Bridge Road, Chennai 600 003 https://www.mhc.tn.gov.in/judis WP No. 25020 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 25020 of 2026 and W.M.P.Nos.27295 & 27298 of 2026 10-07-2026 https://www.mhc.tn.gov.in/judis