WP No. 29071 of 2026 __________ Page1 of 4 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 06-08-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 29071 of 2026 and W.M.P.Nos.31890 & 31891 of 2026 Arunperumal, Proprietor of Tvl. Arunperumal and Co Shop No.2, No.15/6, South Mada Street, Mylapore, Chennai - 600004. ..Petitioner(s) Vs The Assistant Commissioner (ST) Proprietor of Tvl. Arunperumal and Co Shop No.2, No.15/6, South Mada Street, Mylapore, Chennai - 600004 ..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 order passed u/s.73 of CGST Act, 2017 dated 24.12.2025 in Reference No.ZD331225372754B and a summary order in FORM GST DRC-07 dated 24.12.2025 in Reference No.ZD331225372754B on the file of the Respondent relating to F.Y.2021-22 and quash the same. For Petitioner(s): Mr.K.G.Jayasuriya for Ms.Janani N For Respondent(s): Mr.R.Sethu Prabakaran, Government Advocate (Tax) *********** https://www.mhc.tn.gov.in/judis WP No. 29071 of 2026 __________ Page2 of 4 ORDER An order dated 24.12.2025 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 Advocate (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, 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. https://www.mhc.tn.gov.in/judis WP No. 29071 of 2026 __________ Page3 of 4 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. 06-08-2026 (2/2) Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To The Assistant Commissioner (ST) Proprietor of Tvl. Arunperumal and Co Shop No.2, No.15/6, South Mada Street, Mylapore, Chennai - 600004 https://www.mhc.tn.gov.in/judis WP No. 29071 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 29071 of 2026 and W.M.P.Nos.31890 & 31891 of 2026 06-08-2026 (2/2) https://www.mhc.tn.gov.in/judis