WP No. 27986 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. 27986 of 2026 and W.M.P.Nos.30650 & 30652 of 2026 Foodie Crunch, Represented by its Proprietor, Mahamed Arif Residing at No.2/20, 1st Street, Kon Krishna Nagar, West Tambaram, Chennai 600 045 ..Petitioner(s) Vs The Deputy State Tax Officer 1, Tambaram Assessment Circle Room No.121, 1st Floor, Commercial Taxes Building, Greenways Road, Raja Annamalaipuram, Chennai-600 028 ..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 relating to the impugned proceedings of the Respondent in GSTIN 33BMJPA1173L1Z8/ 2021-22, culminating in the Assessment Order dated 01.12.2025, passed under Section 73 of the CGST/TNGST Act, 2017, bearing Reference No. ZD331225017708I, along with the consequential Form GST DRC-07 dated 01.12.2025, and quash all the impugned proceedings as passed contrary to the provisions of the CGST/TNGST Act, 2017, and against the principles of natural justice. https://www.mhc.tn.gov.in/judis WP No. 27986 of 2026 __________ Page2 of 4 For Petitioner(s): Mr.Rajkumar P For Respondent(s): Ms.Amirta Poonkodi Dinakaran, Government Counsel (Tax) ******* ORDER An order dated 01.12.2025 is assailed on the ground that the petitioner did not have a reasonable opportunity to contest the tax demand on merits. 2. Ms.Amirta Poonkodi Dinakaran, 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 pursuant thereto. He refers to the document at page 33 of the paper book. This aspect is required to be verified and confirmed. https://www.mhc.tn.gov.in/judis WP No. 27986 of 2026 __________ Page3 of 4 5. Subject to verifying and confirming that not less than 25% of the tax demand under the impugned order was recovered earlier, the impugned order is set aside 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 from the date of verifying and confirming the above mentioned recovery. Subject to fulfilment of the above condition in relation to the demand under the impugned order, 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. 30-07-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To The Deputy State Tax Officer 1, Tambaram Assessment Circle Room No.121, 1st Floor, Commercial Taxes Building, Greenways Road, Raja Annamalaipuram, Chennai-600 028 https://www.mhc.tn.gov.in/judis WP No. 27986 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 27986 of 2026 and W.M.P.Nos.30650 & 30652 of 2026 30-07-2026 https://www.mhc.tn.gov.in/judis