W.P.(MD) No.22531 of 2026 BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT DATED: 07.08.2026 CORAM: THE HONOURABLE MR.JUSTICE C.SARAVANAN W.P.(MD) No.22531 of 2026 and W.M.P.(MD) No.16761 of 2026 Tvl.Gayathiri Jewellers Rep.by its Proprietor Murugiah Balasubramanian ... Petitioner /vs./ The State Tax Officer / Commercial Tax Officer Tirunelveli Town Assessment Circle Tirunelveli. ... Respondent PRAYER: Writ Petition filed under Article 226 of the Constitution of India for issuance of Writ of Certiorarified Mandamus, calling for the impugned assessment order on the file of respondent vide GSTIN 33AHZPB8464H2ZV/2022-23 and in summary order Reference No. ZD3304262177487 dated 27.04.2026 and quash the same as illegal and devoid of merits and direct the respondent to redo the assessment proceedings for the year 2022-23. For Petitioner : Mr.Raja Karthikeyan For Respondent : Ms.Sudarkodi Natchiyar Government Advocate (Tax) 1/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No.22531 of 2026 ORDER Ms.Sudarkodi Natchiyar, learned Government Advocate (Tax), takes notice for the respondent. 2.By consent, this writ petition is disposed of at the time of admission after hearing the learned counsel for the petitioner and the learned Government Advocate (Tax) for the respondent. 3.This writ petition has been filed challenging the impugned order passed by the respondent bearing Ref.No.GSTIN 33AHZPB8464H2ZV/2022-23 and in summary order Reference No. ZD3304262177487 dated 27.04.2026, for the assessment year 2022-23, which was preceded by a show cause notice in Form GST DRC-01 dated 20.01.2025. 4.The petitioner was also issued with reminders on 01.08.2025, 12.08.2025 and 20.08.2025, which called upon the petitioner to file a reply and to appear for a personal hearing. The Petitioner however neither filed any reply nor appeared for personal hearings. Thus, the impugned order has been passed. 2/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No.22531 of 2026 5.When the matter is taken up for hearing today, the learned counsel for the petitioner submits that the petitioner is willing to pre-deposit 10% of the disputed tax as a condition for de novo adjudication and has also made an endorsement to that effect in the Court Bundle, which reads as under:- “I giving consent to pay 10% of the disputed tax.” 6.Recording the same, the impugned order passed by the respondent bearing Ref.No.GSTIN:33AHZPB8464H2ZV/2022-23 and in summary order Reference No. ZD3304262177487 dated 27.04.2026 is hereby quashed and the case is remitted back to the respondent to pass a fresh order subject to the petitioner depositing 10% of the disputed tax in cash from the petitioner's electronic cash register within a period of thirty days from the date of receipt of a copy of this order. 7.Within such time, the petitioner shall also file a reply to the show cause notice in GST DRC-01 dated 20.01.2025 together with requisite documents to substantiate the case by treating the impugned order dated 27.04.2026 as an addendum to the show cause notice dated 20.01.2025. 3/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No.22531 of 2026 8.In case, the petitioner complies with the above stipulations, the 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 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. 9.It is made clear that the bank attachment shall be lifted subject to the deposit of 10% of the disputed tax as ordered above and the petitioner not being in arrears of any other amount for any other tax period barring the amount demanded under the impugned order. 10.In case, the petitioner fails to comply with any of the stipulations, the 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. 11.Needless to state, before passing any such order, the respondent shall issue due notice on the petitioner. 4/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No.22531 of 2026 12.This Writ Petition stands disposed of with the above observations. No costs. Consequently, connected Miscellaneous Petition is closed. Index : Yes / No 07.08.2026 Internet : Yes / No mm To The State Tax Officer / Commercial Tax Officer Tirunelveli Town Assessment Circle Tirunelveli. 5/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No.22531 of 2026 C.SARAVANAN, J. mm W.P.(MD) No.22531 of 2026 07.08.2026 6/6 https://www.mhc.tn.gov.in/judis