WP No. 27159 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. 27159 of 2026 and W.M.P.No.29722 of 2026 Fresh Flowers GSTIN 33BYNPP9164Q1ZC Represented by its Proprietor Poonamkumari, No.41A, Ground floor, West Lokamanya street, Coimbatore 641 002 ..Petitioner(s) Vs The Deputy Commercial Tax officer RS Puram circle coimbatore ..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 pertaining to the impugned order in Form GST DRC-07 bearing reference no. ZD331225373276E/2021-2022 dated 24.12.2025 issued by the Respondent and quash the same. For Petitioner(s): Mr.G.Derrick Sam For Respondent(s): Ms.Amirta Poonkodi Dinakaran, Government Counsel (Tax) ******** https://www.mhc.tn.gov.in/judis WP No. 27159 of 2026 __________ Page2 of 4 ORDER An order dated 24.12.2025 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 about 26% of the tax demand under the impugned order was recovered earlier. 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 tax demand 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. 27159 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. 24-07-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To The Deputy Commercial Tax officer RS Puram circle coimbatore https://www.mhc.tn.gov.in/judis WP No. 27159 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 27159 of 2026 and W.M.P.No.29722 of 2026 24-07-2026 https://www.mhc.tn.gov.in/judis