WP No. 26092 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. 26092 of 2026 and W.M.P.Nos.28487 & 28489 of 2026 Ambika Agency, Rep by its Proprietrix Mrs Anita Popatlal No.53, Strotten Muthiah Mudali Street, Sowcarpet, Chennai 600 079 ..Petitioner(s) Vs 1. The Deputy Commissioner CT, GST Appeals, Chennai North, Greams Road, Chennai 600 006 2. The State Tax Officer, NSC Bose Road Assessment Circle Room No.314, Third Floor, Integrated Commercial Taxes Building, Wall Tax Road, Chennai 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, call for the records of the 2nd Respondent in order dated 29.12.2025 in GSTIN 33AAGPP9847G1ZC/2021-22 bearing Reference No. ZD3312254230901 and the consequential rejection of appeal order dated 03.06.2026 in FORM GST APL-02 bearing Reference No. ZD3306260264589 passed by the 1st Respondent and quash the same as illegal, arbitrary and in violation of principle of natural justice. https://www.mhc.tn.gov.in/judis WP No. 26092 of 2026 __________ Page2 of 4 For Petitioner(s): Ms.Darshita R For Respondent(s): Ms.G.Dhana Madhri, Government Counsel (Tax) ********** ORDER An order dated 29.12.2025 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 respondents. 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. 26092 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 1. The Deputy Commissioner CT, GST Appeals, Chennai North, Greams Road, Chennai 600 006 2. The State Tax Officer, NSC Bose Road Assessment Circle Room No.314, Third Floor, Integrated Commercial Taxes Building, Wall Tax Road, Chennai 600 003 https://www.mhc.tn.gov.in/judis WP No. 26092 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 26092 of 2026 and W.M.P.Nos.28487 & 28489 of 2026 20-07-2026 https://www.mhc.tn.gov.in/judis