WP No. 25477 of 2026 __________ Page1 of 4 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 15-07-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 25477 of 2026 and W.M.P.Nos.27772 & 27773 of 2026 M/s. Dhanam S Sampath Traders Represented by its Proprietor, Mr J Sampath Kumar Jayaraman 181/B/6, Sirumugai Road, Mettupalayam, Coimbatore 641301 GSTIN- 33BQWPS9527D1Z8 ..Petitioner(s) Vs 1. The Deputy State Tax Officer (ST) I Office of the Assistant commissioner (ST), Mettupalayam Taluk Assessment circle, Mettupalayam , Coimbatore district 2. The Assistant Commissioner (ST) Office of the Assistant Commissioner (ST) Mettupalayam Taluk Assessment circle, Mettupalayam , Coimbatore district ..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 Order in FORM GST DRC-07 bearing Ref No. ZD331225311980P dated 19.12.2025 passed by the Respondent and the consequential Final Notice for Recovery of Tax dated 04.04.2026 bearing https://www.mhc.tn.gov.in/judis WP No. 25477 of 2026 __________ Page2 of 4 Demand ID ZD331225311980P issued by the 2nd respondent and quash the same. For Petitioner(s): Mr.Sashinyaa Ramesh For Respondent(s): Ms.G.Dhana Madhri, Government Counsel (Tax) ********* ORDER An order dated 19.12.2025 and the recovery notice issued on that basis are challenged on the ground that the petitioner did not have a reasonable opportunity to submit supporting documents. 2. Ms.G.Dhana Madhri, learned Government Counsel (Tax), accepts notice on behalf of the respondents. 3. On perusal of the impugned order, it is evident that the petitioner’s reply was rejected as unsupported by evidence. The writ petition has been filed after the period of limitation expired. 4. On instructions, learned counsel for the petitioner agrees to remit 50% of the disputed tax demand 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. 25477 of 2026 __________ Page3 of 4 5. Subject to the condition that the petitioner remits 50% 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 50% 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. 15-07-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To 1. The Deputy State Tax Officer (ST) I Office of the Assistant commissioner (ST), Mettupalayam Taluk Assessment circle, Mettupalayam , Coimbatore district 2. The Assistant Commissioner (ST) Office of the Assistant Commissioner (ST) Mettupalayam Taluk Assessment circle, Mettupalayam , Coimbatore district https://www.mhc.tn.gov.in/judis WP No. 25477 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 25477 of 2026 and W.M.P.Nos.27772 & 27773 of 2026 15-07-2026 https://www.mhc.tn.gov.in/judis