WP(MD) No. 22219 of 2026 __________ Page1 of 5 BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT DATED: 06-08-2026 CORAM THE HON'BLE MR JUSTICE C. SARAVANAN WP(MD) No. 22219 of 2026 and W.M.P.(MD)No.16570 of 2026 M/s.Sun Pet Bottle Scraps and PSK Cotton Shirts and Dhoties Rep.by its Proprietor V. Palaniyappan, GSTIN 33AJJPP2756J1ZX, 2/635, Palaniyee Nagar, Y. Othakadai, Madurai. ..Petitioner(s) Vs The Deputy State Tax Officer II Melur Assessment Circle, Madurai. ..Respondent(s) Writ Petition, filed under Article 226 of the Constitution of India, praying this court to issue a Writ of Certiorari, calling for the records in the impugned Order in GSTIN 33AJJPP2756J1ZX/2021-22 dated 31.12.2025 issued by the Respondent and quash the same as it is without jurisdiction and clear violation of statutory provisions or pass such other orders as this Hon’ble court may deem fit and proper in the circumstances of the case and thus render justice. For Petitioner(s): Mr.S Karunakar For Respondent(s): Mr.R.Parthiban Special Government Pleader https://www.mhc.tn.gov.in/judis WP(MD) No. 22219 of 2026 __________ Page2 of 5 ORDER Mr.R.Parthiban, learned Special Government Pleader takes notice for the respondent. 2. This Writ Petition is taken up for final hearing at the time of admission with the consent of the learned counsel for the petitioner and the learned Special Government Pleader for the respondent. 3. In this Writ Petition, the petitioner has challenged the Impugned Order dated 31.12.2025 of the respondent bearing reference in GSTIN 33AJJPP2756J1ZX/2021-22. 4. The Impugned Order was preceded by a Show Cause Notice in GST DRC 01 dated 24.09.2025 and the petitioner has not filed his reply and he had not been provided an opportunity to submit documents to substantiate the same and thus, suffered the Impugned Order dated 31.12.2025. 5. 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 29.07.2026. https://www.mhc.tn.gov.in/judis WP(MD) No. 22219 of 2026 __________ Page3 of 5 6. 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 de novo adjudication. 7. The learned counsel for the petitioner has also made an endorsement to that effect in the Court Bundle, which is extracted hereunder:- “Petitioner undertakes to pay 25% tax” 8. In view of the above, the impugned order is 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 (30) days from the date of receipt of a copy of this order. 9. Within such time, the petitioner shall also file a reply to the Show Cause Notice in DRC 01 dated 24.09.2025 together with requisite documents to substantiate the case by treating the Impugned Order dated 31.12.2025 as an Addendum to the Show Cause Notice dated 24.09.2025. 10. 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 (3) months of such reply / pre-deposit. https://www.mhc.tn.gov.in/judis WP(MD) No. 22219 of 2026 __________ Page4 of 5 11. 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. 12. Needless to state, before passing any such order, the respondent shall give due notice to the petitioner. 13. This Writ Petition stands disposed of, with the above observations. No costs. Consequently, connected Writ Miscellaneous Petition is closed. 06-08-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No smn2 To The Deputy State Tax Officer II Melur Assessment Circle, Madurai. https://www.mhc.tn.gov.in/judis WP(MD) No. 22219 of 2026 __________ Page5 of 5 C.SARAVANAN, J. smn2 WP(MD) No. 22219 of 2026 06-08-2026 https://www.mhc.tn.gov.in/judis