WP No. 21974 of 2026 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 19-06-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 21974 of 2026 and WMP.No.23838 of 2026 Zion Enviro Systems Private Limited Rep by its Director, Samraj Ravikumar Edwin, DP7, Sidco Industrial Estate, Putlure, Thaneerkulam, Tiruvallur, Tamil Nadu -602 003. ..Petitioner Vs The Assistant Commissioner (ST) Tiruvallur Assessment Circle, No.4/109, Bangalore Highway, Nazarathpet, Chennai- 123. ..Respondent Prayer : Writ Petition is filed under Article 226 of the Constitution of India praying for issuance of Writ of Certiorari to call for the records relating to the Order in GSTIN:33AAACZ2381E1ZK/2021-22 dated 24-12-2025 passed by the respondent and quash the same as without jurisdiction, contrary to law, contrary to the instructions on Standing Operative Procedures for scrutiny of returns by the respondent. For Petitioner: Mr. M.A.Mudimannan For Respondent: Mr. R. Sethu Prabakaran Government Counsel (Tax) __________ Page1 of 4 https://www.mhc.tn.gov.in/judis WP No. 21974 of 2026 ORDER An order dated 24.12.2025 is assailed in this writ petition on the ground of alleged breach of principles of natural justice. 2. Mr. R.Sethu Prabakaran, learned Government Counsel (Tax), accepts notice on behalf of the respondent.

3. The period of limitation for filing an appeal has expired. On instructions, learned counsel for the petitioner agrees to pay 50% of the disputed tax demand as a condition for remand. An endorsement to that effect is made on the bundle. 4. Subject to the condition that the petitioner remits 50% of the disputed tax demand, as agreed to, 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 50% of the disputed tax demand. __________ Page2 of 4 https://www.mhc.tn.gov.in/judis WP No. 21974 of 2026 5. The writ petition is disposed of on the above terms. Consequently, connected miscellaneous petition is closed. There shall be no order as to costs. 19-06-2026 Index : Yes/No Neutral Citation : Yes/No KJ To The Assistant Commissioner (ST) Tiruvallur Assessment Circle, No.4/109, Bangalore Highway, Nazarathpet, Chennai- 123. __________ Page3 of 4 https://www.mhc.tn.gov.in/judis WP No. 21974 of 2026 SENTHILKUMAR RAMAMOORTHY, J. KJ WP No. 21974 of 2026 and WMP.No.23838 of 2026 19-06-2026 __________ Page4 of 4 https://www.mhc.tn.gov.in/judis

WP No. 21974 of 2026 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 19-06-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 21974 of 2026 and WMP.No.23838 of 2026 Zion Enviro Systems Private Limited Rep by its Director, Samraj Ravikumar Edwin, DP7, Sidco Industrial Estate, Putlure, Thaneerkulam, Tiruvallur, Tamil Nadu -602 003. ..Petitioner Vs The Assistant Commissioner (ST) Tiruvallur Assessment Circle, No.4/109, Bangalore Highway, Nazarathpet, Chennai- 123. ..Respondent Prayer : Writ Petition is filed under Article 226 of the Constitution of India praying for issuance of Writ of Certiorari to call for the records relating to the Order in GSTIN:33AAACZ2381E1ZK/2021-22 dated 24-12-2025 passed by the respondent and quash the same as without jurisdiction, contrary to law, contrary to the instructions on Standing Operative Procedures for scrutiny of returns by the respondent. For Petitioner: Mr. M.A.Mudimannan For Respondent: Mr. R. Sethu Prabakaran Government Counsel (Tax) __________ Page1 of 4 https://www.mhc.tn.gov.in/judis WP No. 21974 of 2026 ORDER An order dated 24.12.2025 is assailed in this writ petition on the ground of alleged breach of principles of natural justice. 2. Mr. R.Sethu Prabakaran, learned Government Counsel (Tax), accepts notice on behalf of the respondent.

3. The period of limitation for filing an appeal has expired. On instructions, learned counsel for the petitioner agrees to pay 50% of the disputed tax demand as a condition for remand. An endorsement to that effect is made on the bundle. 4. Subject to the condition that the petitioner remits 50% of the disputed tax demand, as agreed to, 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 50% of the disputed tax demand. __________ Page2 of 4 https://www.mhc.tn.gov.in/judis WP No. 21974 of 2026 5. The writ petition is disposed of on the above terms. Consequently, connected miscellaneous petition is closed. There shall be no order as to costs. 19-06-2026 Index : Yes/No Neutral Citation : Yes/No KJ To The Assistant Commissioner (ST) Tiruvallur Assessment Circle, No.4/109, Bangalore Highway, Nazarathpet, Chennai- 123. __________ Page3 of 4 https://www.mhc.tn.gov.in/judis WP No. 21974 of 2026 SENTHILKUMAR RAMAMOORTHY, J. KJ WP No. 21974 of 2026 and WMP.No.23838 of 2026 19-06-2026 __________ Page4 of 4 https://www.mhc.tn.gov.in/judis