WP No. 29312 of 2026 __________ Page1 of 4 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 07-08-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 29312 of 2026 and W.M.P.No.32204 of 2026 Healer Surgical Square GSTIN. 33A1ZPR7280A1ZV Represented by its Proprietor B Rafi 784 D, Chenniappan Complex, Ambethkar Nagar, Chettipalayam, Podanur, Coimbatore 641 021 ..Petitioner(s) Vs The Commercial Tax Officer Podanur Assessment Circe Coimbatore. ..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 pertaining to the impugned order in Form GST DRC 07 bearing reference no. ZD3303241124025/2018-19 dated 19.03.2024 issued by the Respondent and quash the same. For Petitioner(s): Mr.S.Arvindh for Mr.Durairaj S For Respondent(s): Ms.G.Dhana Madhri, Special Government Pleader (Tax) ********** https://www.mhc.tn.gov.in/judis WP No. 29312 of 2026 __________ Page2 of 4 ORDER An order dated 19.03.2024 is assailed on the ground of alleged breach of principles of natural justice. 2. Ms.G.Dhana Madhri, learned Special Government Pleader (Tax), accepts notice on behalf of the respondent. 3. Learned counsel for the petitioner submits that two issues were dealt with in the impugned order. As regards the issue relating to invalid ITC under Section 16(4), he submits that returns were filed within the extended time limit specified under Section 16(5). With regard to the mismatch between the petitioner’s GSTR 1 and GSTR 3B returns, he submits that the petitioner agrees to remit the entire tax demand pertaining to this issue as a condition for remand. An endorsement to that effect has been made on the bundle. 4. With regard to invalid ITC under Section 16(4), the impugned order records the date of filing of returns. Since such returns were filed within the extended time limit under Section 16(5), the impugned order is set aside with regard to this issue. As regards the mismatch between the petitioner’s GSTR 1 and GSTR 3B returns, subject to the remittance of the entire tax demand relating thereto, the matter is remanded for re-consideration by setting aside the https://www.mhc.tn.gov.in/judis WP No. 29312 of 2026 __________ Page3 of 4 order. After providing a reasonable opportunity to the petitioner, a fresh order shall be issued only in relation to the mismatch between the petitioner’s GSTR 1 and GSTR 3B returns within three months from the date of remittance of the 100% of the tax demand relating thereto. 5. 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. 07-08-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To The Commercial Tax Officer Podanur Assessment Circe Coimbatore. https://www.mhc.tn.gov.in/judis WP No. 29312 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 29312 of 2026 and W.M.P.No.32204 of 2026 07-08-2026 https://www.mhc.tn.gov.in/judis