WP No. 25961 of 2026 __________ Page1 of 4 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 17-07-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 25961 of 2026 and W.M.P.No.28345 of 2026 M/s PMS Stores Rep by its Prop Khadar Vali .P 16/184, Longley Road, Shevapet, Salem, Tamil Nadu, 636002 ..Petitioner(s) Vs Assistant Commissioner ST Office of the Assistant commissioner Sevapet Assessment Circle, Salem ..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 proceedings passed by the Respondent in the order vide GSTIN 33ANTPK6493K1Z8/2020-2021, dated 14.02.2025 along with Consequential order through FORM GST DRC-07 bearing Ref No ZD330225134419K, dated 14.02.2025 under section 73 of the act for the financial year 2020-2021, to quash the same. For Petitioner(s): Ms.Priyadharshini for Ms.R. Hemalatha https://www.mhc.tn.gov.in/judis WP No. 25961 of 2026 __________ Page2 of 4 For Respondent(s): Ms.Amirta Poonkodi Dinakaran, Government Counsel (Tax) *********** ORDER An order dated 14.02.2025 is assailed on the ground that the petitioner did not have a reasonable opportunity to contest the tax demand on merits. 2. Ms.Amirta Poonkodi Dinakiran, 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. https://www.mhc.tn.gov.in/judis WP No. 25961 of 2026 __________ Page3 of 4 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 petition is closed. There shall be no order as to costs. 17-07-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To Assistant Commissioner ST Office of the Assistant commissioner Sevapet Assessment Circle, Salem https://www.mhc.tn.gov.in/judis WP No. 25961 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 25961 of 2026 and W.M.P.No.28345 of 2026 17-07-2026 https://www.mhc.tn.gov.in/judis