WP No. 22649 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. 22649 of 2026 and WMP.Nos.24563 & 24565 of 2026 AVSD Groups Rep by its proprietor Mrs. Nirmala V. Having office at No.54/3, Sundaram street, Vilankurinchi, Coimbatore - 641035. ..Petitioner Vs The Assistant Commissioner (ST) Saravanampatti west circle, Coimbatore - III. ..Respondent Prayer : Writ Petition is filed under Article 226 of the Constitution of India praying for issuance of Writ of Certiorari to call for the records pertaining to the order dated 17.12.2025 in GSTN : 33AZUPN6224G1Z4/2021-22 and Consequential order along with Form GST DRC - 07 in Reference No. ZD3312252727980 passed by the respondent, and quash the same. For Petitioner: Mr. K Sathish Kumar For Respondent: Ms. Amirta Poonkodi Dinakaran Government Counsel (Tax) ORDER An order dated 17.12.2025 is assailed in this writ petition on the ground that the petitioner was not provided a reasonable opportunity to establish that the supplies are exempt. https://www.mhc.tn.gov.in/judis WP No. 22649 of 2026 __________ Page2 of 4 2. Ms. Amirta Poonkodi Dinakaran, learned Government Counsel (Tax), accepts notice on behalf of the respondent. 3. The period of limitation for filing an appeal has expired. On instructions, learned counsel for the petitioner agrees to pay 50% of the disputed tax demand as a condition for remand. An endorsement to that effect is made on the bundle. 4. Subject to the condition that the petitioner remits 50% of the disputed tax demand, as agreed to, 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 50% of the disputed tax demand. 5. The writ petition is disposed of on the above terms. Consequently, connected miscellaneous petitions are closed. There shall be no order as to costs. 22-07-2026 Index : Yes/No Neutral Citation : Yes/No KJ https://www.mhc.tn.gov.in/judis WP No. 22649 of 2026 __________ Page3 of 4 To The Assistant Commissioner (ST) Saravanampatti west circle, Coimbatore - III. https://www.mhc.tn.gov.in/judis WP No. 22649 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. KJ WP No. 22649 of 2026 and WMP.Nos.24563 & 24565 of 2026 22-07-2026 https://www.mhc.tn.gov.in/judis