WP No. 26844 of 2026 __________ Page1 of 4 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 27-07-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 26844 of 2026 and W.M.P.No.29395 of 2026 M/s. Sakthi Stores Rep.by its Proprietor Mr. Natesan Pillai Chokkalingam, 169, Mahali Amman Koil street, Coimbatore, Tamil Nadu-641 001 ..Petitioner(s) Vs The Deputy State Tax Officer R.S.Puram 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. ZD331225396552B dated 26.12.2025 under Section 73 of the CGST/TNGST Act, 2017 for the Financial Year 2021- 22, and uploaded the same along with the summary of order in DRC07 from the files of the respondent herein, QUASH the same. For Petitioner(s): Ms.Aparna Nandakumar For Respondent(s): Mr.R.Sethu Prabakaran, Government Counsel (Tax) ************* https://www.mhc.tn.gov.in/judis WP No. 26844 of 2026 __________ Page2 of 4 ORDER An order dated 26.12.2025 is assailed primarily on the ground that the petitioner did not have a reasonable opportunity to submit supporting documents. 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 the entire tax demand pursuant to the impugned order was recovered. He has handed over documents evidencing such recovery. This aspect is required to be verified and confirmed. 5. Subject to verifying and confirming that the entire tax demand under the impugned order was recovered, the impugned order is set aside so as to provide an opportunity to the petitioner to submit documents to establish that the discrepancy between the GSTR 1 and GSTR 3B returns arose on account of exempt supplies and the matter is remanded for re-consideration. After https://www.mhc.tn.gov.in/judis WP No. 26844 of 2026 __________ Page3 of 4 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. 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. 27-07-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To The Deputy State Tax Officer R.S.Puram Assessment Circle, Coimbatore, Tamil Nadu https://www.mhc.tn.gov.in/judis WP No. 26844 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 26844 of 2026 and W.M.P.No.29395 of 2026 27-07-2026 https://www.mhc.tn.gov.in/judis