WP No. 27257 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. 27257 of 2026 and W.M.P.No.29849 of 2026 Sree Subramaniam Traders rep by its Prop. A. Subramaniyam 2/226, Amman Nagar, Unjavelampatti, Pollachi- 642003 Coimbatore District ..Petitioner(s) Vs The State Tax officer Pollachi (East)Assessment circle commercial Taxes building Pollachi-642 001 coimbatore District ..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 of the Respondent in his proceedings in GSTIN: 33FMJPS1127NlZO/2021-22 dated 29.12.2025 and quash the same as illegal. For Petitioner(s): Mr.S.Ramanathan For Respondent(s): Mr.R.Sethu Prabakaran, Government Counsel (Tax) ********* https://www.mhc.tn.gov.in/judis WP No. 27257 of 2026 __________ Page2 of 4 ORDER An order dated 29.12.2025 is assailed on the ground that the petitioner did not have a reasonable opportunity to contest the tax demand on merits. 2. Mr.R.Sethu Prabakaran, 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 a sum of about Rs.8,77,000/- was recovered pursuant to the impugned order. He submits further that this is more than 50% of the tax demand. 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 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 reasonable opportunity to the petitioner, a fresh order shall be issued within https://www.mhc.tn.gov.in/judis WP No. 27257 of 2026 __________ Page3 of 4 three months from the date of confirming the above mentioned recovery. Subject to fulfilment of the above condition, the bank attachment shall stand raised. 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 State Tax officer Pollachi (East)Assessment circle commercial Taxes building Pollachi-642 001 coimbatore District https://www.mhc.tn.gov.in/judis WP No. 27257 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 27257 of 2026 and W.M.P.No.29849 of 2026 24-07-2026 https://www.mhc.tn.gov.in/judis