WP No. 11805 of 2026 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 27-03-2026 CORAM THE HON'BLE MR JUSTICE C. SARAVANAN WP No. 11805 of 2026 AND WMP.Nos.12880 and 12881 of 2026 M/s Star Medics Rep by its Sole Proprietor Mr Ramaiyah Ilan Selvan, GSTIN 33ACCPI1302F1ZJ,having shop at,No 10, Mariamman Kovil street, Suramangalam, Salem 636005. ..Petitioner(s) Vs 1. Assistant Commissioner State Tax Officer Hasthampatty Assessment Circle Salem, Commercial Taxes Department Pitchards Road, Adaikala nagar, hasthampatti, Salem, Tamil nadu 636 007 2. Commercial Tax Officer Hasthampatty Assessment Circle Salem Commercial Taxes Department Pitchards Road Adaikala Nagar Hasthampatti Salem Tamil Nadu 636007 3. Indian Overseas Bank Limited Suramangalam Branch No. 4 Subramania Nagar II Salem 636 005 __________ Page1 of 7 https://www.mhc.tn.gov.in/judis WP No. 11805 of 2026 ..Respondent(s) Prayer: Writ Petition filed under Article 226 of the Constitution of India, for issuance of a Writ of Certiorarified Mandamus, call for the records of the Respondent No. 1 vide impugned order dated 25.01.2025 bearing reference no. GSTIN33ACCPI1302F1ZJ/2020-21 and consequently quash the order passed by the 1st Respondent under section 73 bearing reference number ZD330125232913P dated 25.01.2025 and direct the 3rd Respondent Bank to defreeze the accounts of the petitioner i.e., A/c. No. 024602000001695 and its Proprietor A/c. No. 0246010000200 maintained in the 3rd Respondent bank and pass such further or other orders. For Petitioner(s): Mr.Leeban Arivalagan For Respondent(s): Mrs.P.Selvi Government Advocate for R1 and R2 ORDER Mrs.P.Selvi, learned Government Advocate takes notice for the Respondents 1 and 2. 2. This Writ Petition is being disposed of at the stage of admission itself with the consent of the learned counsel for the Petitioner and the learned Government Advocate for the Respondents 1 and 2. __________ Page2 of 7 https://www.mhc.tn.gov.in/judis WP No. 11805 of 2026 3. In this Writ Petition, the Petitioner has challenged the impugned Order dated 25.01.2025, which was preceded by a Show Cause Notice in GST DRC-01 dated 12.09.2024 wherein the Petitioner was called upon to appear for personal hearing. However, the Petitioner had not taken advantage of the same and thus, suffered the impugned Order dated 25.01.2025. 4. It is noticed that the limitation for filing an appeal under Section 107 of the respective GST enactments, 2017 against the impugned Order has already expired. The present Writ Petition has been filed only on 23.03.2026. 5. At this stage, the learned counsel for the Petitioner submits that the Petitioner is willing to pre-deposit 25% of the disputed tax as a condition for denovo adjudication. 6. The learned counsel for the Petitioner has also made an endorsement to that effect in the Court bundle, which is extracted hereunder:- “ As per Petitioner instructions undertake 25% deposit” __________ Page3 of 7 https://www.mhc.tn.gov.in/judis WP No. 11805 of 2026 7. In view of the above, the case is remitted back to the 1st Respondent to pass a fresh order on merits subject to the Petitioner depositing 25% of the disputed tax in cash or from the Petitioner's Electronic Cash Register within a period of thirty (30) days from the date of receipt of a copy of this order. 8. Within such time, the Petitioner shall also file a reply to the Show Cause Notice in GST DRC-01 dated 12.09.2024 together with requisite documents to substantiate the case by treating the impugned Order dated 25.01.2025 as an addendum to the Show Cause Notice dated 12.09.2024. 9. In case the Petitioner complies with the above stipulations, the 1st Respondent shall proceed to pass a final order on merits and in accordance with law as expeditiously as possible, preferably, within a period of three (3) months of such reply/pre-deposit. Subject to the Petitioner complying with the above stipulations, the attachment of the bank account of the Petitioner if any, shall also stand automatically vacated. 10. It is made clear that bank attachment shall be lifted subject to the Petitioner depositing 25% of the disputed tax as ordered above and the __________ Page4 of 7 https://www.mhc.tn.gov.in/judis WP No. 11805 of 2026 Petitioner not being in arrears of any other amount for any other tax period barring the amount demanded under the impugned Order. 11. In case the Petitioner fails to comply with any of the stipulations, the 1st Respondent is at liberty to proceed against the Petitioner to recover the tax in accordance with law as if this Writ Petition was dismissed in limine today. 12. Needless to state, before passing any such order, the 1st Respondent shall give due notice to the Petitioner. 13. This Writ Petition stands disposed of with the above observations. No costs. Connected Writ Miscellaneous Petitions are closed. 27-03-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No Vv __________ Page5 of 7 https://www.mhc.tn.gov.in/judis WP No. 11805 of 2026 To 1. Assistant Commissioner State Tax Officer Hasthampatty Assessment Circle Salem, Commercial Taxes Department Pitchards Road, Adaikala nagar, hasthampatti, Salem, Tamil nadu 636 007 2. Commercial Tax Officer Hasthampatty Assessment Circle Salem Commercial Taxes Department Pitchards Road Adaikala Nagar Hasthampatti Salem Tamil Nadu 636007 3. Indian Overseas Bank Limited Suramangalam Branch No. 4 Subramania Nagar II Salem 636 005 __________ Page6 of 7 https://www.mhc.tn.gov.in/judis WP No. 11805 of 2026 C.SARAVANAN, J. VV WP No. 11805 of 2026 27-03-2026 __________ Page7 of 7 https://www.mhc.tn.gov.in/judis WP No. 11805 of 2026 __________ Page8 of 7 https://www.mhc.tn.gov.in/judis