W.P.No.13541 of 2026 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED : 09.04.2026 CORAM THE HONOURABLE MR.JUSTICE C.SARAVANAN W.P.No.13541 of 2026 and W.M.P.Nos.14804 & 14807 of 2026 Tvl. Senthilvel Fefrtilizers, Represented by its Proprietor Mrs. Samadharaman Ponnie, No.31, Ramachandra Reddy Street, Thiruvayarpadi, Tiruvallur, Tamil Nadu, 601204. ... Petitioner Vs. The Assistant Commissioner, Ponneri Assessment Circle, Survey No.1275/3, Integrated Commercial Taxes Office Complex, Chennai (North) Division, First Floor, Room No.106, D.No:32, Elephant Gate Bridge Road, Chennai – 600003. ... Respondent Writ Petition filed under Article 226 of the Constitution of India, for issuance of a Writ of Certiorari, calling for the records on the files of the Respondent herein in the impugned order in FORM GST DRC-07 with Reference No. ZD3302250849349 dated 08.02.2025 along with the detailed order in GSTIN/33AKSPP6924A1Z3/2020-21 dated 08.02.2025 for the tax period April 2020 - March 2021 and quash the same. 1/6 https://www.mhc.tn.gov.in/judis W.P.No.13541 of 2026 For Petitioner : Mr. S. Kamala Kanth For Respondent : Mr.C.Harsha Raj Special Government Pleader ORDER Mr.C.Harsha Raj, learned Special Government Pleader, takes notice for the respondent. 2. With the consent of the learned counsel for the petitioner and the learned Special Government Pleader for the respondent, this writ petition is being disposed of at the time of admission. 3. In this Writ Petition, the petitioner has challenged the impugned Order dated 08.02.2025 passed under Section 73 of the respective GST enactments for the tax period 2020-2021. 4. By the impugned order, the demand proposed in the Show Cause Notice in DRC-01 dated 26.11.2024 was confirmed, as the petitioner failed to reply to the said notice. 2/6 https://www.mhc.tn.gov.in/judis W.P.No.13541 of 2026 5. It is noticed that the statutory limitation for filing an appeal under Section 107 of the respective GST enactments against the impugned order has already expired. The present writ petition has been filed only on 06.04.2026. 6. The learned counsel for the petitioner would submit that the petitioner is willing to deposit 25% of the disputed tax confirmed by the impugned order, and therefore, the learned counsel seeks one opportunity for de novo adjudication. The learned counsel also made an endorsement in the bundle to the following effect: “The petitioner accepted the 25% of Tax dispute value by petitioner counsel” 7. Recording the same, the case is remitted back to the respondent to pass a fresh order on merits, subject to the petitioner depositing 25% of the disputed tax confirmed by the impugned order either in cash or 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. 3/6 https://www.mhc.tn.gov.in/judis W.P.No.13541 of 2026 8. Within such time, the petitioner shall also file a reply to the impugned Show Cause Notice dated 26.11.2024 together with requisite documents to substantiate their case by treating the impugned Order dated 08.02.2025 as an addendum to the said notice. 9. Subject to the petitioner complying with the above stipulations, the respondent shall proceed to pass fresh order on merits and in accordance with law, as expeditiously as possible, preferably within a period of three (3) months of such reply / deposit. 10. It is needless to state that, before passing any such order, the petitioner shall be heard. 11. The attachment of the petitioner’s bank account shall also stand automatically raised/vacated, subject to the petitioner complying with the above stipulations. 12. 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 4/6 https://www.mhc.tn.gov.in/judis W.P.No.13541 of 2026 not being in arrears of any other amount for any other tax period barring the amount demanded under the impugned order. 13. 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. 14. This writ petition stands disposed of with the above directions. Consequently, connected miscellaneous petitions are closed. No costs. 09.04.2026 raja Neutral Citation : Yes / No To The Assistant Commissioner, Ponneri Assessment Circle, Survey No.1275/3, Integrated Commercial Taxes Office Complex, Chennai (North) Division, First Floor, Room No.106, D.No:32, Elephant Gate Bridge Road, Chennai – 600003. 5/6 https://www.mhc.tn.gov.in/judis W.P.No.13541 of 2026 C.SARAVANAN, J. raja W.P.No.13541 of 2026 09.04.2026 6/6 https://www.mhc.tn.gov.in/judis