WP No. 32043 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. 32043 of 2026 and W.M.P.Nos.35244 & 35245 of 2026 Ameed Abdulla Proprietor of M/s. Andavar Steels No.l76A, Near Hotel Tamil Nadu, Krishnagiri Bye Pass Road, Hosur, Krishnagiri District, Tamil Nadu. ..Petitioner(s) Vs 1. Deputy Commissioner (CT) Hosur, Krishnagiri District, Tamil Nadu-635 109. 2. The Assistant Commissioner (ST) Hosur (South) -III, Krishnagiri District Tamil Nadu-635 109. ..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 impugned assessment order in Ref. No. ZD330326060034V dated 09.03.2026 passed by the 2nd Respondent under Section 74 of the CGST/TNGST Act, 2017 along with the summary of the order in DRC-07 for the Financial Year 2019-20 and the subsequent original impugned appeal rejection order dated 15.07.2026 passed by the 1st Respondent in GST APL-02, and quash the same as being https://www.mhc.tn.gov.in/judis WP No. 32043 of 2026 __________ Page2 of 4 violative of principles of natural justice and contrary to the provisions of the CGST/SGST Acts, 2017. For Petitioner(s): Ms.Sushmitha.S For Respondent(s): Ms.Amirta Poonkodi Dinakaran, Additional Government Pleader (Tax) ******** ORDER An order dated 09.03.2026 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 Additional Government Pleader (Tax), accepts notice on behalf of the respondents. 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 10% pre-deposit was made while filing the appeal. On instructions, it is submitted that the petitioner agrees to remit an additional 15% as a condition for remand. An endorsement to that effect has been made on the bundle. https://www.mhc.tn.gov.in/judis WP No. 32043 of 2026 __________ Page3 of 4 5. Subject to the remittance of an additional 15% of the petitioner of the tax demand within thirty days from the date of receipt of a copy of this order, the impugned order is set aside so as to provide a reasonable opportunity to the petitioner to contest the tax demand on merits and the matter is remanded for re- consideration. After providing a reasonable opportunity to the petitioner, a fresh order shall be issued within five months from the date of remittance of an additional 15% 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 1. Deputy Commissioner (CT) Hosur, Krishnagiri District, Tamil Nadu-635 109. 2. The Assistant Commissioner (ST) Hosur (South) -III, Krishnagiri District Tamil Nadu-635 109. https://www.mhc.tn.gov.in/judis WP No. 32043 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 32043 of 2026 and W.M.P.Nos.35244 & 35245 of 2026 20-08-2026 https://www.mhc.tn.gov.in/judis