WP No. 27919 of 2026 __________ Page1 of 4 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 30-07-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 27919 of 2026 and W.M.P.Nos.30579 & 30581 of 2026 Tvl Sri Vinayaga Traders, Represented by its Proprietor Varadaraj Udayar Selvaraj No. 346, Gandhi Nagar, Thachur, Kallakurichi, Villupuram 606 202 ..Petitioner(s) Vs Deputy State Tax Officer 1, Kallakuruchi Assessment Circle No 103/5 Nepal street, Kallakurichi 606 202 ..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 in GSTIN No 33ECIPS0818G1ZM/2021-22 on the files of the Respondent and quashing the impugned order dated 10-12-2025 with the reference no. ZD331225150018T for the FY 2021-22 passed by the Respondent as arbitrary. For Petitioner(s): Mr.Kabil Dev S For Respondent(s): Mr.R.Sethu Prabakaran, Government Counsel (Tax) ********** https://www.mhc.tn.gov.in/judis WP No. 27919 of 2026 __________ Page2 of 4 ORDER An order dated 10.12.2025 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 the entire tax demand under the impugned order was recovered. He has handed over a copy of the electronic liability ledger in this regard. This aspect is required to be verified and confirmed. 5. Subject to verifying and confirming that the tax demand under the impugned order was recovered earlier, 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 three months https://www.mhc.tn.gov.in/judis WP No. 27919 of 2026 __________ Page3 of 4 from the date of confirming the above mentioned recovery. Subject to fulfilment of the above condition, the bank attachment relating to the impugned order shall be 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. 30-07-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To Deputy State Tax Officer 1, Kallakuruchi Assessment Circle No 103/5 Nepal street, Kallakurichi 606 202 https://www.mhc.tn.gov.in/judis WP No. 27919 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 27919 of 2026 and W.M.P.Nos.30579 & 30581 of 2026 30-07-2026 https://www.mhc.tn.gov.in/judis