WP No. 25853 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. 25853 of 2026 and W.M.P.Nos.28242 & 28243 of 2026 Kabeerdass Suresh Pro.Of New Revathy Store, 18/352, Main Road, Pennadam-606 105 ..Petitioner(s) Vs Deputy State Tax Officer Office of the State Tax officer(ST) Chidambaram-II Assessment circle ..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 relating to the impugned order passed by the Respondent in GSTIN No. 33EDTPS6945E1ZX/2021-22 dated 04.11.2025 together with the Summary of Order issued in FORM GST DRC-07 bearing Reference No. ZD3311250567786 dated 04.11.2025 and the consequential FORM DRC 01 D dated 23.02.2026, quash the same, and consequently, direct the Respondent to reconsider the matter afresh by permitting the Petitioner to submit all relevant records, documents and objections, and thereafter pass orders on merits after affording an opportunity of personal hearing to the Petitioner. https://www.mhc.tn.gov.in/judis WP No. 25853 of 2026 __________ Page2 of 4 For Petitioner(s): Mr..Prashanth Kiran For Respondent(s): Mr.R.Sethu Prabakaran, Government Counsel (Tax) ********* ORDER An order dated 04.11.2025 is assailed on the ground that the petitioner did not have a reasonable opportunity to contest the tax demand on merits. 2. Mr.R.Sethu Prabakaran, 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 more than 50% of the tax demand under the impugned order was recovered from the petitioner’s electronic credit ledger. This aspect is required to be verified and confirmed. 5. Subject to verifying and confirming that more than 50% of the tax https://www.mhc.tn.gov.in/judis WP No. 25853 of 2026 __________ Page3 of 4 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 three months from the date of verifying and confirming the recovery. 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. 17-07-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To Deputy State Tax Officer Office of the State Tax officer(ST) Chidambaram-II Assessment circle https://www.mhc.tn.gov.in/judis WP No. 25853 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 25853 of 2026 and W.M.P.Nos.28242 & 28243 of 2026 17-07-2026 https://www.mhc.tn.gov.in/judis