WP No. 32038 of 2026 __________ Page1 of 4 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 20-08-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 32038 of 2026 and W.M.P.Nos.35242 & 35243 of 2026 Jayalakshmi Stores And Cool Drinks And ARAVINILAYAM, Represented by its Partner, M.Srlinivasan, No.91/52,Arcot Road, Kodambakkam, Chennai -600024. ..Petitioner(s) Vs Deputy Commercial Taxofficier KODAMBAKKAM CENTRAL III, Chennai,Tamilnadu ..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 impugned assessment order on the file of the respondent under Section 73 of the CGST/TNGST Act, 2017 for the Assessment Year 2021-2022 alleging discrepancy in the exempted turnover reported in the GST returns. Thereafter, the respondent passed the impugned Assessment Order in Reference No. ZD331225309653M dated 19.12.2025 for the assessment year (APR 2021- MAR 2022), and quash the same as illegal and devoid of merits. https://www.mhc.tn.gov.in/judis WP No. 32038 of 2026 __________ Page2 of 4 For Petitioner(s): M/s.S.Nareshkumar For Respondent(s): Ms.G.Dhana Madhri, Special Government Pleader (Tax) *********** ORDER An order dated 19.12.2025 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 Special Government Pleader (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. 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, https://www.mhc.tn.gov.in/judis WP No. 32038 of 2026 __________ Page3 of 4 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 remittance of 25% of the disputed tax demand. 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. 20-08-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To Deputy Commercial Taxofficier KODAMBAKKAM CENTRAL III, Chennai,Tamilnadu https://www.mhc.tn.gov.in/judis WP No. 32038 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 32038 of 2026 and W.M.P.Nos.35242 & 35243 of 2026 20-08-2026 https://www.mhc.tn.gov.in/judis