WP No. 26412 of 2026 __________ Page1 of 5 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 21-07-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 26412 of 2026 and W.M.P.Nos.28882 & 28883 of 2026 Santhoshkumar Proprietor, Tvl. SS Agency,18, Kali Street, Annadhanappatti, Salem, Tamil Nadu. 636 002 ..Petitioner(s) Vs 1. The Assistant Commissioner ST FAC Annatnanapatty Assessment Circle, Commercial taxes office Building pitchards Raod, Hasthampatty Salem 636 007 2. The State Tax Officer also known as Commercial Tax Officer, Office of the Assistant Commissioner ST,Annathanapatty Assessment Circle, Salem Division, Salem - I, Tamil Nadu. 3. The Branch Manager Laxmi Vilas Bank Ltd, M S Jari Kondalampattti 180, Calicutmain Road, Kondalampatti, Salem. ..Respondent(s) https://www.mhc.tn.gov.in/judis WP No. 26412 of 2026 __________ Page2 of 5 PRAYER: Writ Petition filed under Article 226 of The Constitution of India praying for the issuance of a Writ of Certiorarified Mandamus, call for the records on the files of the 2nd Respondent herein in DRC-07 Reference No ZD331225322676H dated 20.12.2025, Order under section 73 of the TNGST Act, 2017 and the summary of the order in Form GST DRC-07 both dated 20.12.2025 issued in Reference No. ZD331225322676H for the tax period 2021-22 and consequential order passed by the 1st respondent in GSTIN No. 33GTFPS4139N1Z3/2026/A2 dated 05.06.2026 and quash the same and consequently direct the 1st respondent to lift the attachment of the petitioners Bank Account No.659360000000586 held by the petitioner in the 3rd respondent bank. For Petitioner(s): Mr.Jayaprathap A N R For Respondent(s): Ms.Amirta Poonkodi Dinakaran, Government Counsel (Tax) *********** ORDER An order dated 20.12.2025 is assailed on the ground that the petitioner did not have a reasonable opportunity to contest the tax demand on merits. https://www.mhc.tn.gov.in/judis WP No. 26412 of 2026 __________ Page3 of 5 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. 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. 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. Subject to fulfilment of the above condition, the bank attachment shall stand raised. https://www.mhc.tn.gov.in/judis WP No. 26412 of 2026 __________ Page4 of 5 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 1. The Assistant Commissioner ST FAC Annatnanapatty Assessment Circle, Commercial taxes office Building pitchards Raod, Hasthampatty Salem 636 007 2. The State Tax Officer also known as Commercial Tax Officer, Office of the Assistant Commissioner ST,Annathanapatty Assessment Circle, Salem Division, Salem - I, Tamil Nadu. 3. The Branch Manager Laxmi Vilas Bank Ltd, M S Jari Kondalampattti 180, Calicutmain Road, Kondalampatti, Salem. https://www.mhc.tn.gov.in/judis WP No. 26412 of 2026 __________ Page5 of 5 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 26412 of 2026 and W.M.P.Nos.28882 & 28883 of 2026 21-07-2026 https://www.mhc.tn.gov.in/judis