WP No. 26583 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. 26583 of 2026 and W.M.P.Nos.29082 & 29085 of 2026 Sunvis Systems Private Limited Represented by its Director, Mrs Jothi R, Ground and First, No 1 Aranmanai Thottam, Sunvis, Sangaralinganar Road, Opp to The Camford International School, Ganapathy, Coimbatore- 641006 ..Petitioner(s) Vs Deputy State Tax Officer II PN Palayam Assessment Circle, Combined Commercial Taxes Building, Dr.Balasundaram Road, Coimbatore- 641 018. ..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 relating to the Impugned Order bearing GSTIN No. 33AASCS5554Q2ZE/2021-22 dated 25.11.2025 along with its Summary in Form GST DRC-07 bearing reference ZD331125425497F dated 25.11.2025 issued by the Respondent, to quash the same. For Petitioner(s): Mr.Dhanesh for Ms.Disha Jain https://www.mhc.tn.gov.in/judis WP No. 26583 of 2026 __________ Page2 of 4 For Respondent(s): Ms.Amirta Poonkodi Dinakaran, Government Counsel (Tax) ********* ORDER An order dated 25.11.2025 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 the total demand under the impugned order towards CGST and SGST were recovered from the petitioner’s electronic liability ledger. He places reliance on pages 57 to 59 of the paper book. He submits, on instructions, that the petitioner agrees to remit 25% of the IGST demand. An endorsement has been made to that effect on the bundle. https://www.mhc.tn.gov.in/judis WP No. 26583 of 2026 __________ Page3 of 4 5. Subject to verifying and confirming the recovery of tax dues as asserted by the petitioner and subject further to the remittance of 25% of the IGST demand within thirty days from the date of receipt of a copy of this order, the impugned order is set aside so as to provide an opportunity to the petitioner to contest the matter on merits 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 in the manner specified above. 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 Deputy State Tax Officer II PN Palayam Assessment Circle, Combined Commercial Taxes Building, Dr.Balasundaram Road, Coimbatore- 641 018. https://www.mhc.tn.gov.in/judis WP No. 26583 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 26583 of 2026 and W.M.P.Nos.29082 & 29085 of 2026 22-07-2026 https://www.mhc.tn.gov.in/judis