WP No. 23170 of 2026 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 29-06-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 23170 of 2026 and WMP.Nos.25114 & 25116 of 2026 M/s MS Foods (Represented by its proprietor Mr. V. Murugan) Ana Nagar, 237E-3A-1, Kurichi, Sundarapuram, Coimbatore 641024. ..Petitioner Vs The Deputy State Tax Officer - 1 Kuniyamuthur Assessment Circle, Coimbatore 18. ..Respondent Prayer : Writ Petition is filed under Article 226 of the Constitution of India praying for issuance of Writ of Certiorari calling for the records in the Impugned Order passed by the Respondent in Form GST DRC 07 vide Order Ref No. ZD3312251071233 dated 08.12.2025 along with its accompanying detailed order and quash the same. For Petitioner: M/s. Jaya Suriya K G For Respondent: Ms. Amirta Poonkodi Dinakaran Government Counsel (Tax) ORDER An order dated 08.12.2025 is assailed in this writ petition on the ground of alleged breach of principles of natural justice. __________ Page1 of 4 https://www.mhc.tn.gov.in/judis WP No. 23170 of 2026 2. Ms. Amirta Poonkodi Dinakaran, 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 25% 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 25% 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 25% of the disputed tax demand. 5. The writ petition is disposed of on the above terms. Consequently, connected miscellaneous petitions are closed. There shall be no order as to costs. 29-06-2026 Index : Yes/No Neutral Citation : Yes/No KJ __________ Page2 of 4 https://www.mhc.tn.gov.in/judis WP No. 23170 of 2026 To The Deputy State Tax Officer - 1 Kuniyamuthur Assessment Circle, Coimbatore 18. __________ Page3 of 4 https://www.mhc.tn.gov.in/judis WP No. 23170 of 2026 SENTHILKUMAR RAMAMOORTHY, J. KJ WP No. 23170 of 2026 and WMP.Nos.25114 & 25116 of 2026 29-06-2026 __________ Page4 of 4 https://www.mhc.tn.gov.in/judis

WP No. 23170 of 2026 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 29-06-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 23170 of 2026 and WMP.Nos.25114 & 25116 of 2026 M/s MS Foods (Represented by its proprietor Mr. V. Murugan) Ana Nagar, 237E-3A-1, Kurichi, Sundarapuram, Coimbatore 641024. ..Petitioner Vs The Deputy State Tax Officer - 1 Kuniyamuthur Assessment Circle, Coimbatore 18. ..Respondent Prayer : Writ Petition is filed under Article 226 of the Constitution of India praying for issuance of Writ of Certiorari calling for the records in the Impugned Order passed by the Respondent in Form GST DRC 07 vide Order Ref No. ZD3312251071233 dated 08.12.2025 along with its accompanying detailed order and quash the same. For Petitioner: M/s. Jaya Suriya K G For Respondent: Ms. Amirta Poonkodi Dinakaran Government Counsel (Tax) ORDER An order dated 08.12.2025 is assailed in this writ petition on the ground of alleged breach of principles of natural justice. __________ Page1 of 4 https://www.mhc.tn.gov.in/judis WP No. 23170 of 2026 2. Ms. Amirta Poonkodi Dinakaran, 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 25% 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 25% 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 25% of the disputed tax demand. 5. The writ petition is disposed of on the above terms. Consequently, connected miscellaneous petitions are closed. There shall be no order as to costs. 29-06-2026 Index : Yes/No Neutral Citation : Yes/No KJ __________ Page2 of 4 https://www.mhc.tn.gov.in/judis WP No. 23170 of 2026 To The Deputy State Tax Officer - 1 Kuniyamuthur Assessment Circle, Coimbatore 18. __________ Page3 of 4 https://www.mhc.tn.gov.in/judis WP No. 23170 of 2026 SENTHILKUMAR RAMAMOORTHY, J. KJ WP No. 23170 of 2026 and WMP.Nos.25114 & 25116 of 2026 29-06-2026 __________ Page4 of 4 https://www.mhc.tn.gov.in/judis