W.P.(MD) No. 21062 of 2026 BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT DATED: 27.07.2026 CORAM: THE HONOURABLE MR.JUSTICE C.SARAVANAN W.P.(MD) No. 21062 of 2026 and W.M.P.(MD) No.15639 of 2026 M/s.Jumbo Sweets and Bakery, rep. by it Partner R.Sidhrangathan ... Petitioner Vs The Deputy State Tax Officer – 11, Nanguneri Assessment Circle, Commercial Taxes Office Building, Perumbattu, Kalakadu Road, Nanguneri - Tirunelveli – 627108. ... Respondent PRAYER: Writ Petition filed under Article 226 of the Constitution of India for issuance of Writ of Certiorarified Mandamus calling for the impugned order on the file of the Respondent vide GSTIN 33ABBFM6490N1ZV/2021-22 dated 08.12.2025 and quash the same which was uploaded only in the GST Portal after cancellation of the Registration of the Petitioner and further direct the Respondent to pass assessment order afresh after providing opportunity of Personal Hearing. 1/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No. 21062 of 2026 For petitioner : Mr. J.Madhusuthanan For respondent : Mr.S.Venkatesh Counsel for State of TN ***** ORDER Mr.S.Venkatesh, learned Counsel for State of TN, takes notice for the respondent. 2. This Writ Petition is taken up for final hearing 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 GSTIN 33ABBFM6490N1ZV/2021-22 dated 08.12.2025 of the respondent, which was preceded by a Show Cause Notice in DRC 01 dated 16.09.2025, wherein 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 08.12.2025. 2/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No. 21062 of 2026 4. 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 22.07.2026. 5. 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. 6. The learned counsel for the petitioner has also made an endorsement to that effect in the Court Bundle, which is extracted hereunder:- “Agreed to pay 25% of the disputed tax as per the directions of the Court.” 7. In view of the above, the impugned order is quashed and 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. 3/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No. 21062 of 2026 8. Within such time, the petitioner shall also file a reply to the Show Cause Notice in DRC 01 dated 16.09.2025 together with requisite documents to substantiate the case by treating the Impugned Order dated 08.12.2025 as an addendum to the Show Cause Notice dated 16.09.2025. 9. 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. Subject to the Petitioner complying with the above stipulations, the attachment of the bank account of the petitioner shall also stand automatically vacated. 10. It is made clear that bank attachment shall be lifted subject to the deposit of 25% of the disputed tax as ordered above and the petitioner not being in arrears of any other amount for any other tax period barring the amount demanded under the impugned Order. 11. In case the petitioner fails to comply with any of the stipulations, the 4/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No. 21062 of 2026 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. 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 27.07.2026 Internet : Yes / No (1/2) apd To The Deputy State Tax Officer – 11, Nanguneri Assessment Circle, Commercial Taxes Office Building, Perumbattu, Kalakadu Road, Nanguneri - Tirunelveli – 627108. 5/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No. 21062 of 2026 C.SARAVANAN, J. apd W.P.(MD) No. 21062 of 2026 27.07.2026 (1/2) 6/6 https://www.mhc.tn.gov.in/judis