W.P.No.12416 of 2026 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED : 27.03.2026 CORAM : THE HONOURABLE MR.JUSTICE C.SARAVANAN W.P.No.12416 of 2026 and W.M.P.Nos.13571 and 13573 of 2026 M/s. Spark Automation rep. By its Proprietrix Nadarajan Ruby PL No.86, No.44/1A1, Sri Metha Nagar Kundrathur Chennai 600 069. … Petitioner Vs The State Tax Officer Sriperumbudur Assessment Circle 4/109 Bangalore Chennai Highway Varadarajapuram, Nazarathpet Chennai 600 123. … Respondent Prayer: Writ Petition filed under Article 226 of the Constitution of India, for issuance of a Writ of Certiorari, to call for the records pertaining to the impugned order passed by the respondent against petitioner’s firm vide GSTIN:33AZLPR1672F1Z9 in Order Reference No.ZD3311253916865 dated 22.11.2025 for the Assessment Year 2021 – 2022 and quash the same. 1/6 https://www.mhc.tn.gov.in/judis W.P.No.12416 of 2026 For Petitioner : Mr.K.M.Malarmannan For Respondent : Mr.TNC.Kaushik Additional Government Pleader - - - - - ORDER Mr.TNC.Kaushik, learned Additional Government Pleader 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 Additional Government Pleader for the Respondent. 3. In this Writ Petition, the Petitioner has challenged the impugned Order dated 22.11.2025, which was preceded by a Show Cause Notice in GST DRC-01 dated 24.09.2025 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 22.11.2025. 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 2/6 https://www.mhc.tn.gov.in/judis W.P.No.12416 of 2026 already expired long before. However, the present Writ Petition has been filed only on 26.03.2026. 5. At this stage, the learned counsel for the Petitioner submits that the Petitioner is willing to pre-deposit 10% of the disputed tax as a condition for denovo adjudication. 6. The learned counsel for the Petitioner has made the following endorsement to that effect in the Court bundle which has been extracted hereunder:- “Petitioner undertakes to pay 10% of the disputed tax.” 7. Recording the above consent, the case is remitted back to the Respondent to pass a fresh order on merits subject to the Petitioner depositing 10% 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 3/6 https://www.mhc.tn.gov.in/judis W.P.No.12416 of 2026 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 22.11.2025 as an addendum to the Show Cause Notice dated 24.09.2025. 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 10% 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 4/6 https://www.mhc.tn.gov.in/judis W.P.No.12416 of 2026 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. Connected Writ Miscellaneous Petitions are closed. 27.03.2026 Neutral Citation: Yes / No jai To: The State Tax Officer Sriperumbudur Assessment Circle 4/109 Bangalore Chennai Highway Varadarajapuram, Nazarathpet Chennai 600 123. 5/6 https://www.mhc.tn.gov.in/judis W.P.No.12416 of 2026 C.SARAVANAN, J. jai W.P.No.12416 of 2026 27.3.2026 6/6 https://www.mhc.tn.gov.in/judis