WP No. 27597 of 2026 __________ Page1 of 4 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 28-07-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 27597 of 2026 and W.M.P.Nos.30248 & 30249 of 2026 Arumugam Balasundaram (Trade Name B.C.Ceramics) Rep. by its Proprietor IFS -12, NA, Industrial Estate, Vridhachalam, Cuddalore, Tamil Nadu-606002 ..Petitioner(s) Vs 1. Deputy Commercial Tax Officer Virudhachalam Cuddalore, Cuddalore Tamil nadu 2. Assistant Commissioner (ST) Virudhachalam. ..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 Order of Assessment in DRC-07 bearing Reference No ZD331225424268J in GSTIN/ ID 33AYPPB0277P1Z3 / APR 2021 - MAR 2022 dated 29.12.2025 passed by the respondent and to quash the same and further direct the respondent to release the Order of Attachment in Form GST DRC 13 dated 10.04.2026 issued by the respondent. For Petitioner(s): Mr.R Ganesh Kanna https://www.mhc.tn.gov.in/judis WP No. 27597 of 2026 __________ Page2 of 4 For Respondent(s): Ms.G.Dhana Madhri, Government Counsel (Tax) ********** 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. Ms.G.Dhana Madhri, learned Government Counsel (Tax), accepts notice on behalf of the respondents. 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. On instructions, learned counsel for the petitioner agrees to remit 25% of the disputed tax demand as a condition for remand. An endorsement to that effect has been made on the bundle. 5. Subject to the condition that the petitioner remits 25% of the disputed tax demand within thirty days from the date of receipt of a copy of this order, the impugned order is set aside and the matter is remanded for re-consideration. https://www.mhc.tn.gov.in/judis WP No. 27597 of 2026 __________ Page3 of 4 After providing a reasonable opportunity to the petitioner, a fresh order shall be issued within three months from the date of remittance of 25% of the disputed tax demand. 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 petitions are closed. There shall be no order as to costs. 28-07-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To 1. Deputy Commercial Tax Officer Virudhachalam Cuddalore, Cuddalore Tamil nadu 2. Assistant Commissioner (ST) Virudhachalam. https://www.mhc.tn.gov.in/judis WP No. 27597 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 27597 of 2026 and W.M.P.Nos.30248 & 30249 of 2026 28-07-2026 https://www.mhc.tn.gov.in/judis