W.P.(MD) No. 20544 of 2026 BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT DATED: 21.07.2026 CORAM: THE HONOURABLE MR.JUSTICE C.SARAVANAN W.P.(MD) No. 20544 of 2026 and W.M.P.(MD) No.15217 of 2026 Tvl Balaji Constructions, rep. by its Parner R.Vengadesan. ... Petitioner Vs The Deputy State Tax Offrcer - 1 / Deputy Commercial Tax Officer, Rajapalayam -I Assessment Circle, Virudhunagar. ... Respondent PRAYER: Writ Petition filed under Article 226 of the Constitution of India for issuance of Writ of Certiorarified Mandamus calling for the impugned assessment order on the file of respondent vide GSTIN 33AASFB7501M1Z7/2020-21 and in summary order Reference No ZD330225230164Y dated 22.02.2025 and quash the same as illegal and devoid of merits and direct the respondent to redo the assessment proceedings for the year 2020-21. For petitioner : Mr. Raja Karthikeyan 1/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No. 20544 of 2026 For respondent : M/s.P.Sudarkodi Natchiyar Counsel for State of TN ***** ORDER M/s.P.Sudarkodi Natchiyar, learned Counsel for State of TN, takes notice for the respondent. 2. This Writ Petition is being disposed of at the time of admission with the consent of the learned counsel for the petitioner and learned Counsel for State of TN for the respondent. 3. In this Writ Petition, the petitioner has challenged the Impugned Order in FORM GST DRC-07 bearing Ref.No. GSTIN 33AASFB7501M1Z7/2020-21 dated 22.02.2025 of the respondent, wherein the demand proposed in Show Cause Notice in DRC 01 dated 07.02.2024 has been confirmed. After the issuance of the Impugned Order, the petitioner has filed an application dated 31.07.2025 for rectification of the Impugned Assessment Order dated 22.02.2025, which came to be rejected by order dated 10.10.2025. 2/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No. 20544 of 2026 4. By the Show Cause Notice in DRC 01 dated 07.02.2024, the petitioner was also called upon to appear for personal hearing. However, the petitioner had not taken advantage of the same and thus, suffered the impugned Order dated 22.02.2025. 5. It is noticed that the limitation for filing an appeal under Section 107 of the respective GST enactments, 2017 against the impugned Order has already expired. The present Writ Petition has been filed only on 17.07.2026. 6. At this stage, the learned counsel for the petitioner submits that the Petitioner is willing to pre-deposit 25% of the disputed tax as a condition for de novo adjudication. 7. The learned counsel for the petitioner has also made an endorsement to that effect in the Court Bundle, which is extracted hereunder:- “The petitioner pay to 25% disputed tax as instructed by the Hon’ble High Court.” 3/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No. 20544 of 2026 8. In view of the above, the case is remitted back to the respondent to pass a fresh order subject to the petitioner depositing 25% of the disputed tax in cash from the petitioner's Electronic Cash Register within a period of thirty (30) days from the date of receipt of a copy of this order. 9. Within such time, the Petitioner shall also file a reply to the Show Cause Notice in DRC 01, dated 07.02.2024 together with requisite documents to substantiate the case by treating the Impugned Order dated 22.02.2025 as an addendum to the Show Cause Notice dated 07.02.2024. 10. In case the petitioner complies with the above stipulations, the respondent shall proceed to pass a final order on merits and in accordance with law as expeditiously as possible, preferably, within a period of three (3) months of such reply / pre-deposit. 11. In case the petitioner fails to comply with any of the stipulations, the respondent is at liberty to proceed against the petitioner to recover the tax in accordance with law as if this Writ Petition was dismissed in limine today. 4/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No. 20544 of 2026 12. Needless to state, before passing any such order, the respondent shall give due notice to the petitioner. 13. This Writ Petition stands disposed of with the above observations. No costs. Consequently, connected Writ Miscellaneous Petition is closed. Index : Yes / No 21.07.2026 Internet : Yes / No apd To The Deputy State Tax Offrcer - 1 / Deputy Commercial Tax Officer, Rajapalayam -I Assessment Circle, Virudhunagar. 5/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No. 20544 of 2026 C.SARAVANAN, J. apd W.P.(MD) No. 20544 of 2026 21.07.2026 6/6 https://www.mhc.tn.gov.in/judis