1/7 WP No. 11971 of 2026 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 27-03-2026 CORAM THE HONOURABLE MR JUSTICE C. SARAVANAN WP No. 11971 of 2026 and WMP Nos. 13068 & 13071 of 2026 Tvl Amico Packaging Industries Rep. by its proprietor - Janaki Raman, Old No.244, New No.106, Jaganathapuram Road, Athipedu Village, Irulipattu, Alinjivakkam Post, Ponneri Taluk, Tiruvallur – 600067. GSTIN 33BKWPJ1345Q1ZI Petitioner(s) Vs The Assistant Commissioner (ST) (FAC) Office of the Commercial Tax Officer, Ponneri Assessment Circle, Station Integrated Commercial Taxes Building (North) Division, First Floor, Room No.106, No.32, Elephant Gate Bridge Road, Vepery, Chennai - 600 003. Respondent(s) PRAYER Writ Petition filed under Article 226 of the Constitution of India for issuance of a Writ of Certiorari, calling for the records of the impugned proceedings of the Respondent in GSTIN 33BKWPJ1345Q1ZI/2022-2023 dated 12.07.2023 and the consequential Summary Order of the impugned proceedings vide Form GST DRC-07 in Reference No.ZD3307230478390 dated 12.07.2023 for the Tax Period April 2022 - May 2022. https://www.mhc.tn.gov.in/judis 2/7 WP No. 11971 of 2026 For Petitioner(s): Mr.S.Rajasekar For Respondent(s): Ms.Amirtha Poonkodi Dinakaran Government Advocate ORDER Ms.Amirtha Poonkodi Dinakaran, learned Government Advocate takes notice for the Respondent. 2. This Writ Petition is being disposed of at the stage of admission itself with the consent of the learned counsel for the Petitioner and the learned Government Advocate for the Respondent. 3. In this Writ Petition, the Petitioner has challenged the impugned Order dated 12.07.2023, which was preceded by a Show Cause Notice in GST DRC-01 dated 07.06.2023 wherein the Petitioner was called upon to file a reply and to appear for a personal hearing. However, the Petitioner did not take advantage of the same and has thus suffered the impugned Order dated 12.07.2023. 4. 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 long before. However, the present Writ Petition has been filed only on 24.03.2026. https://www.mhc.tn.gov.in/judis 3/7 WP No. 11971 of 2026 5. At this stage, the learned counsel for the Petitioner submits that the Petitioner is willing to pre-deposit 100% of the disputed tax as a condition for denovo adjudication and he has also made an endorsement to that effect in the Court bundle. 6. The learned counsel for the Petitioner has also made the following endorsement to that effect in the Court bundle which has been extracted hereunder:- “Will Pay 100% of the tax.” 7. Recording the above consent given by the Petitioner, the case is remitted back to the Respondent to pass a fresh order on merits subject to the Petitioner depositing 100% of the disputed tax 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. 8. Within such time, the Petitioner shall also file a reply to the Show Cause Notice in GST DRC-01 dated 07.06.2023 together with requisite documents to substantiate the case by treating the impugned Order dated 12.07.2023 as an addendum to the Show Cause Notice dated 07.06.2023. https://www.mhc.tn.gov.in/judis 4/7 WP No. 11971 of 2026 9. 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. 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. 10. It is made clear that bank attachment shall be lifted subject to the Petitioner depositing 100% 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. 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. https://www.mhc.tn.gov.in/judis 5/7 WP No. 11971 of 2026 13. This Writ Petition stands disposed of with the above observations. No costs. Connected Writ Miscellaneous Petitions are closed. 27-03-2026 (1/2) Index:Yes/No Speaking/Non-speaking order Internet:Yes Neutral Citation:Yes/No ssr https://www.mhc.tn.gov.in/judis 6/7 WP No. 11971 of 2026 To The Assistant Commissioner (ST) (FAC) Office of the Commercial Tax Officer, Ponneri Assessment Circle, Station Integrated Commercial Taxes Building (North) Division, First Floor, Room No.106, No.32, Elephant Gate Bridge Road, Vepery, Chennai - 600 003. https://www.mhc.tn.gov.in/judis 7/7 WP No. 11971 of 2026 C.SARAVANAN J. ssr WP No. 11971 of 2026 27-03-2026 (1/2) https://www.mhc.tn.gov.in/judis