WP No. 26533 of 2026 __________ Page1 of 4 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 22-07-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 26533 of 2026 and W.M.P.Nos.29029 & 29030 of 2026 Laxshe Chem Rep. by its partner Muralikrishna Munirajan, Address-821/B4, Bairamangalam Road, Aggondapalli, Hosur, Krishnagiri, Tamil Nadu- 635 109 ..Petitioner(s) Vs The Deputy State Tax Officer 2 (Also known as the deputy Commercial Tax Officer) Hosur (South)-III, Krishnagiri, Hosur, Tamil Nadu. ..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 on the files of the learned Respondent herein in GSTIN/ 33AAGFL5681A1ZL/ 2021- 22 in FORM GST DRC-07 in Order Reference No. ZD331225182319D dated 12.12.2025, and quash the same. For Petitioner(s): Ms.S. Vishnupriya For Respondent(s): Mr.R.Sethu Prabakaran, Government Counsel (Tax) ************ https://www.mhc.tn.gov.in/judis WP No. 26533 of 2026 __________ Page2 of 4 ORDER An order dated 12.12.2025 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 about 56% of the demand relating to CGST and SGST were recovered and that the recovery exceeds 25% of the total tax demand under the impugned order. This aspect is required to be verified and confirmed. An endorsement to that effect has been made on the bundle. 5. Subject to verifying and confirming that not less than 25% of the total tax demand under the impugned order was recovered, the impugned order is set aside so as to provide an opportunity to the petitioner to contest the tax proposal on merits and the matter is remanded for re-consideration. After providing a https://www.mhc.tn.gov.in/judis WP No. 26533 of 2026 __________ Page3 of 4 reasonable opportunity to the petitioner, a fresh order shall be issued within three months from the date of confirming the above mentioned 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. 22-07-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To The Deputy State Tax Officer 2 (Also known as the deputy Commercial Tax Officer) Hosur (South)-III, Krishnagiri, Hosur, Tamil Nadu. https://www.mhc.tn.gov.in/judis WP No. 26533 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 26533 of 2026 and W.M.P.Nos.29029 & 29030 of 2026 22-07-2026 https://www.mhc.tn.gov.in/judis