WP No. 26424 of 2026 __________ Page1 of 4 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 21-07-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 26424 of 2026 and W.M.P.Nos.28894 & 28895 of 2026 Ms.Gurusive Sasirani Proprietor of Tvl. Sasi Rani, No-8, Ganapathi Nagar, Mayiladuthurai, Nagapattinam - 609001 ..Petitioner(s) Vs The Assistant Commissioner (ST) Office of the Assistant Commissioner (ST) Mayiladuthurai Assessment Circle, No.5, Pookollai, Mayuranathar Keezha Veethi, Mayiladuthurai-609 003 ..Respondent(s) PRAYER: Writ Petition filed under Article 226 of The Constitution of India praying for the issuance of a Writ of Certiorari, call for the records pertaining to the impugned order vide DRC 07 bearing Ref.No. ZD330925084857P dated 08.09.2025 for the year 2024- 2025 issued by the respondent and subsequent original impugned rectification order dated 27.01.2026 in Ref. No. ZD3301261749275 by the respondent and quash the same. For Petitioner(s): Mr.Arvindh S For Respondent(s): Ms.Amirta Poonkodi Dinakaran, Government Counsel (Tax) ************* https://www.mhc.tn.gov.in/judis WP No. 26424 of 2026 __________ Page2 of 4 ORDER An order dated 08.09.2025 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 Dinakaran, 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 about 40% 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 about 40% of the tax demand under the impugned order was recovered, 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 confirming the above mentioned recovery. https://www.mhc.tn.gov.in/judis WP No. 26424 of 2026 __________ Page3 of 4 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. 21-07-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To The Assistant Commissioner (ST) Office of the Assistant Commissioner (ST) Mayiladuthurai Assessment Circle, No.5, Pookollai, Mayuranathar Keezha Veethi, Mayiladuthurai-609 003 https://www.mhc.tn.gov.in/judis WP No. 26424 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 26424 of 2026 and W.M.P.Nos.28894 & 28895 of 2026 21-07-2026 https://www.mhc.tn.gov.in/judis