WP No. 26474 of 2026 __________ Page1 of 4 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 21-07-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 26474 of 2026 and W.M.P.No.28955 of 2026 M/s. Linga Bhairavi Engineering Rep. by its Partner Mr. Rajendran S, 56, Gopalakrishnapuram, Sathy Road, Ganapathy, Coimbatore, Tamil Nadu-641 006. ..Petitioner(s) Vs The Assistant Commissioner (ST) Ganapathy Assessment Circle, Coimbatore, 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, call for the records of the Impugned Assessment Order in Ref. No. ZD331225121265V dated 08.12.2025 under Section 73 of the CGST/TNGST Act, 2017 and uploaded the same along with the summary of order in DRC 07 for the Financial Year 2021-22 from the files of the respondent herein, QUASH the same. For Petitioner(s): Ms.Aparna Nandakumar For Respondent(s): Ms.Amirta Poonkodi Dinakaran, Government Counsel (Tax) ********** https://www.mhc.tn.gov.in/judis WP No. 26474 of 2026 __________ Page2 of 4 ORDER An order dated 25.10.2023 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 more than 25% of the tax demand under the impugned order was recovered. She relies on the electronic liability ledger in this regard. This aspect is required to be verified and confirmed. 5. Subject to verifying and confirming that not less than 25% of the tax demand under the impugned order was recovered, 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 confirming the above mentioned recovery. https://www.mhc.tn.gov.in/judis WP No. 26474 of 2026 __________ Page3 of 4 6. The writ petition is disposed of on the above terms. Consequently, connected writ miscellaneous petition is 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 The Assistant Commissioner (ST) Ganapathy Assessment Circle, Coimbatore, Tamil Nadu. https://www.mhc.tn.gov.in/judis WP No. 26474 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 26474 of 2026 and W.M.P.No.28955 of 2026 21-07-2026 https://www.mhc.tn.gov.in/judis