WP No. 28996 of 2026 __________ Page1 of 4 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 05-08-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 28996 of 2026 and W.M.P.Nos.31795 & 31797 of 2026 Tvl N.SARAVANAN Represented by Its Proprietor Mr N Saravanan No.78, First Floor, Kasim Nagar, Anna Anjugam Street, Kanchipuram 631502. ..Petitioner(s) Vs 1. Deputy Commissioner (CT) Kancheepuram. 2. The Deputy State Tax Officer -1 Kancheepuram Rural Assessment Circle, C.T. Building, Collectorate Campus, Kancheepuram 631501. ..Respondent(s) PRAYER: Writ Petition filed under Article 226 of The Constitution of India praying for the issuance of a Writ of Certiorari, to call for the impugned order dated 29.05.2026 in FORM GST APL-02 in Reference No.ZD330526290293B passed by the 1st respondent and the impugned Order dated 18.12.2025 in Form GST DRC-07 bearing Reference No.ZD331225296522F along with its annexure in Petitioners GSTIN 33BJZPS5346A3ZU for the FY 2021-2022 passed by the 2nd respondent and quash the same. https://www.mhc.tn.gov.in/judis WP No. 28996 of 2026 __________ Page2 of 4 For Petitioner(s): Mr.R.Anishkumar for Mr.Sathiyaraj E. For Respondent(s): Ms.G.Dhana Madhri, Special Government Pleader (Tax) ********** ORDER An order dated 18.12.2025 is assailed on the ground that the petitioner did not have a reasonable opportunity to contest the tax demand on merits. 2. Ms.G.Dhana Madhri, learned Special 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 the 10% pre-deposit was made while lodging the appeal. On instructions, he submits that the petitioner agrees to remit an additional 15% of the disputed tax demand 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. 28996 of 2026 __________ Page3 of 4 5. Subject to the remittance of an additional 15% by the petitioner 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 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. 05-08-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To 1. Deputy Commissioner (CT) Kancheepuram. 2. The Deputy State Tax Officer -1 Kancheepuram Rural Assessment Circle, C.T. Building, Collectorate Campus, Kancheepuram 631501. https://www.mhc.tn.gov.in/judis WP No. 28996 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 28996 of 2026 and W.M.P.Nos.31795 & 31797 of 2026 05-08-2026 https://www.mhc.tn.gov.in/judis