WP No. 22884 of 2026 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 25-06-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 22884 of 2026 and W.M.P.No.24784 of 2026 M/s. Bharani Blue Metals Rep by its proprietor- CNP Bhoobalan, 277/1 B2, Ariyur, Vellore, Tamil Nadu- 632002. ..Petitioner(s) Vs The State Tax Officer Intelligence Office of the Commercial Tax officer, Inspection IV, Vellore Division, Vellore 632 001 ..Respondent(s) PRAYER: Writ Petition filed under Article 226 of The Constitution of India praying for the issuance of a Writ of Certiorari, calling for the records relating to the impugned proceedings passed by the Respondent in the impugned order in GSTIN 33AGBPB6841R1Z8/2020-21 dated 22.01.2024 along with the consequential proceedings under section 74 in FORM GST DRC 07 vide ref. no. ZD3301240939277 dated 22.01.2024 along with consequential proceeding of rectification order vide GSTIN No.33AGBPB6841R1Z8/2020-21 dated 25.11.2024 along with consequential summary of rectification order vide ref no. ZD3311242144108 dated 25.11.2024 for the FY 2020-21 to quash the same. __________ Page1 of 4 https://www.mhc.tn.gov.in/judis WP No. 22884 of 2026 For Petitioner(s): Ms.E.Keerthavarshini For Respondent(s): Mr.R.Sethu Prabakaran, Government Counsel (Tax) ********** ORDER An order dated 22.01.2024 is assailed on the ground that the petitioner did not have a reasonable opportunity to contest the tax demand on merits.

2. Mr.R.Sethu Prabakaran, learned Government Counsel (Tax), accepts notice on behalf of the respondent. 3. On perusal of the impugned order, it is evident that such order was issued without hearing the petitioner. The writ petition has been filed after the period of limitation expired. 4. On instructions, learned counsel for the petitioner agrees to remit 50% of the disputed tax demand as a condition for remand. An endorsement to that effect has been made on the bundle. 5. Subject to the condition that the petitioner remits 50% of the disputed tax demand within thirty days from the date of receipt of a copy of this order, __________ Page2 of 4 https://www.mhc.tn.gov.in/judis WP No. 22884 of 2026 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. 6. The writ petition is disposed of on the above terms. Consequently, connected writ miscellaneous petition is closed. There shall be no order as to costs. 25-06-2026 (3/3) Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To The State Tax Officer Intelligence Office of the Commercial Tax officer, Inspection IV, Vellore Division, Vellore 632 001 __________ Page3 of 4 https://www.mhc.tn.gov.in/judis WP No. 22884 of 2026 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 22884 of 2026

and W.M.P.No.24784 of 2026 25-06-2026 (3/3) __________ Page4 of 4 https://www.mhc.tn.gov.in/judis

WP No. 22884 of 2026 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 25-06-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 22884 of 2026 and W.M.P.No.24784 of 2026 M/s. Bharani Blue Metals Rep by its proprietor- CNP Bhoobalan, 277/1 B2, Ariyur, Vellore, Tamil Nadu- 632002. ..Petitioner(s) Vs The State Tax Officer Intelligence Office of the Commercial Tax officer, Inspection IV, Vellore Division, Vellore 632 001 ..Respondent(s) PRAYER: Writ Petition filed under Article 226 of The Constitution of India praying for the issuance of a Writ of Certiorari, calling for the records relating to the impugned proceedings passed by the Respondent in the impugned order in GSTIN 33AGBPB6841R1Z8/2020-21 dated 22.01.2024 along with the consequential proceedings under section 74 in FORM GST DRC 07 vide ref. no. ZD3301240939277 dated 22.01.2024 along with consequential proceeding of rectification order vide GSTIN No.33AGBPB6841R1Z8/2020-21 dated 25.11.2024 along with consequential summary of rectification order vide ref no. ZD3311242144108 dated 25.11.2024 for the FY 2020-21 to quash the same. __________ Page1 of 4 https://www.mhc.tn.gov.in/judis WP No. 22884 of 2026 For Petitioner(s): Ms.E.Keerthavarshini For Respondent(s): Mr.R.Sethu Prabakaran, Government Counsel (Tax) ********** ORDER An order dated 22.01.2024 is assailed on the ground that the petitioner did not have a reasonable opportunity to contest the tax demand on merits.

2. Mr.R.Sethu Prabakaran, learned Government Counsel (Tax), accepts notice on behalf of the respondent. 3. On perusal of the impugned order, it is evident that such order was issued without hearing the petitioner. The writ petition has been filed after the period of limitation expired. 4. On instructions, learned counsel for the petitioner agrees to remit 50% of the disputed tax demand as a condition for remand. An endorsement to that effect has been made on the bundle. 5. Subject to the condition that the petitioner remits 50% of the disputed tax demand within thirty days from the date of receipt of a copy of this order, __________ Page2 of 4 https://www.mhc.tn.gov.in/judis WP No. 22884 of 2026 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. 6. The writ petition is disposed of on the above terms. Consequently, connected writ miscellaneous petition is closed. There shall be no order as to costs. 25-06-2026 (3/3) Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To The State Tax Officer Intelligence Office of the Commercial Tax officer, Inspection IV, Vellore Division, Vellore 632 001 __________ Page3 of 4 https://www.mhc.tn.gov.in/judis WP No. 22884 of 2026 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 22884 of 2026

and W.M.P.No.24784 of 2026 25-06-2026 (3/3) __________ Page4 of 4 https://www.mhc.tn.gov.in/judis