WP No. 26103 of 2026 __________ Page1 of 4 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 20-07-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 26103 of 2026 and W.M.P.Nos.28503 & 28504 of 2026 S.S Constructions Rep. by its proprietor Sangaiah Subbaiah, No. 148/2, NA, 4TH Block, Kavi Arasu Kannadasan Nagar, Kodungaiyur, Chennai, Tamil Nadu - 600118 ..Petitioner(s) Vs Assistant Commissioner (st) ( Fac) Kodungaiyur Assessment circle, Room No. 203, Integrated Commercial taxes Building Wall Tax Road, Chennai Tamil Nadu 600 003 ..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 bearing GSTIN 33ASNPS4886R1ZH (FY 2021-22) dated 30.12.2025 and its consequential Demand Order dated 30.12.2025 having Reference No. ZD331225449770F issued by the Respondent and quash the same. For Petitioner(s): Mr.Sanskar Samdaria https://www.mhc.tn.gov.in/judis WP No. 26103 of 2026 __________ Page2 of 4 For Respondent(s): Ms.G.Dhana Madhri, Government Counsel (Tax) ************ ORDER An order dated 30.12.2025 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. 26103 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. 20-07-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To Assistant Commissioner (st) ( Fac) Kodungaiyur Assessment circle, Room No. 203, Integrated Commercial taxes Building Wall Tax Road, Chennai Tamil Nadu 600 003 https://www.mhc.tn.gov.in/judis WP No. 26103 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 26103 of 2026 and W.M.P.Nos.28503 & 28504 of 2026 20-07-2026 https://www.mhc.tn.gov.in/judis