WP No. 24881 of 2026 __________ Page1 of 4 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 13-07-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 24881 of 2026 and W.M.P.Nos.27139 & 27140 of 2026 Ramu Agencies Represented by its Proprietor M.Tamilselvan, 8H, 8h, Mangalam Building, Four Roads, Salem - 636009. ..Petitioner(s) Vs The Assistant Commissioner (ST) (FAC) Arisipalayam assessment circle, 3rd floor, commercial taxes office building, pitchards road, hasthampatty, salem-7. ..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 learned Respondent herein in GSTIN/33AAEFR3812P1Z1/2017-18 in FORM GST DRC-07 in Order Reference No. ZD330923021686B dated 05.09.2023 and quash the same. For Petitioner(s): Mr.B.Syed Abdul Wakeel for Mr.Siri Chandana. K For Respondent(s): Ms.G.Dhana Madhri, Government Counsel (Tax) *********** https://www.mhc.tn.gov.in/judis WP No. 24881 of 2026 __________ Page2 of 4 ORDER An order dated 05.09.2023 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 the entire tax demand under the impugned order was recovered pursuant thereto. This aspect is required to be verified and confirmed. 5. Subject to verifying and confirming that the entire tax demand under the impugned order was recovered, the impugned order is set aside so as to provide a reasonable opportunity to the petitioner to contest the tax demand on merits, and the matter is remanded for re-consideration. After providing a reasonable opportunity to the petitioner, a fresh order shall be issued within https://www.mhc.tn.gov.in/judis WP No. 24881 of 2026 __________ Page3 of 4 three months from the date of verifying and confirming that the tax demand was recovered. 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. 13-07-2026 (1/2) Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To The Assistant Commissioner (ST) (FAC) Arisipalayam assessment circle, 3rd floor, commercial taxes office building, pitchards road, hasthampatty, salem-7. https://www.mhc.tn.gov.in/judis WP No. 24881 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 24881 of 2026 and W.M.P.Nos.27139 & 27140 of 2026 13-07-2026 (1/2) https://www.mhc.tn.gov.in/judis