W.P.(MD) No.22584 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.22584 of 2026 and W.M.P.(MD) No.16842 of 2026 Manokaran Muthukrishnan Kiruthika, Proprietor of M/s. Shivam Water Supply ... Petitioner /vs./ Deputy Commercial Tax Officer/Deputy State Tax Officer, Srirangam Assessment Circle 155 Moola Thoppu Road Sriramapuram Tiruchirappalli Tamil Nadu 620006 India. ... Respondent PRAYER: Writ Petition filed under Article 226 of the Constitution of India for issuance of Writ of Certiorari, to call for the records on the file of the Respondent and quash the Impugned Order under section 73 of the Tamil Nadu Goods and Service Tax Act, 2017/Central Goods and Service Tax Act, 2017 including the Summary of the Order in Form GST DRC-07 dated 23.12.2025 and having Reference Number ZD331225353731M and its annexure dated 23.12.2025 ( in GSTIN. 33CETPK5133D1ZL passed by the Respondent for FY 2021-22, pending disposal of the above Writ Petition. 1/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No.22584 of 2026 For Petitioner : Mr.N.V.Balaji For Respondent : Ms.P.Sudarkodi Natchiyar counsel for the State of Tamil Nadu ORDER Ms.P.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 dated 23.12.2025, which was preceded by a show cause notice in Form GST DRC-01 dated 24.09.2025. 4.The petitioner was also issued with reminders on 31.10.2025, 11.11.2025 and 19.11.2025, 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.22584 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 25% 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:- “We undertake to deposit 25% of tax.” 6.Recording the same, the impugned order passed by the respondent dated 23.12.2025 is hereby quashed and the case is remitted back to the respondent to pass a fresh order subject to the petitioner depositing 25% 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 24.09.2025 together with requisite documents to substantiate the case by treating the impugned order dated 23.12.2025 as an addendum to the show cause notice dated 24.09.2025. 8.In case, the petitioner complies with the above stipulations, the respondent shall proceed to pass a final order on merits and in accordance 3/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No.22584 of 2026 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 25% 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.22584 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 Deputy Commercial Tax Officer/Deputy State Tax Officer, Srirangam Assessment Circle 155 Moola Thoppu Road Sriramapuram Tiruchirappalli Tamil Nadu 620006 India. 5/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No.22584 of 2026 C.SARAVANAN, J. mm W.P.(MD) No.22584 of 2026 07.08.2026 6/6 https://www.mhc.tn.gov.in/judis