WP No. 27198 of 2026 __________ Page1 of 4 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 24-07-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 27198 of 2026 and W.M.P.Nos.29782 & 29784 of 2026 Sakthi Constructions Rep by its Partner D.Saravanan No. 5, Subrayapillai Street, Kaveripakkam, Tindivanam 604 001 ..Petitioner(s) Vs 1. The Deputy State Tax Officer Tindivanam , Tindivanam Assessment circle, 2nd Floor, Nehru street, Commercial tax office, Tindivanam 2. The State Tax Officer Review Cell (Intelligence), Cuddalore. ..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 records of the Order passed by the 1st Respondent dated 30.01.2025 with Ref. No. ZD3301252829763 pertaining to the FY 2020-21 and quash the same. For Petitioner(s): Mr.Adithya Reddy For Respondent(s): Ms.Amirta Poonkodi Dinakaran, Government Counsel (Tax) *********** https://www.mhc.tn.gov.in/judis WP No. 27198 of 2026 __________ Page2 of 4 ORDER An order dated 30.01.2025 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 entire SGST component was recovered. He also submits that this represent 50% of the total tax demand. This aspect is also required to be verified and confirmed. An endorsement has been made to that effect on the bundle. 5. Subject to verifying and confirming that not less than 50% 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 demand on merits and the matter is remanded for re-consideration. After providing a https://www.mhc.tn.gov.in/judis WP No. 27198 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. 24-07-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To 1. The Deputy State Tax Officer Tindivanam , Tindivanam Assessment circle, 2nd Floor, Nehru street, Commercial tax office, Tindivanam 2. The State Tax Officer Review Cell (Intelligence) ,Cuddalore. https://www.mhc.tn.gov.in/judis WP No. 27198 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 27198 of 2026 and W.M.P.Nos.29782 & 29784 of 2026 24-07-2026 https://www.mhc.tn.gov.in/judis