WP No. 23706 of 2026 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 02-07-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 23706 of 2026 and W.M.P.Nos.25678 & 25679 of 2026 Shree Shyambaba Container Service Rep. by its Proprietor HANUMAN PILANIA S/o. Satbir Singh, No.17, Umapathy Complex, Shanmuga Nagar Salai, Puranagar Backside, Switha Dental college, Chennai, Tamil Nadu 600077 ..Petitioner(s) Vs The Assistant Commissioner Ambattur Industrial Estate, Ambattur, Kancheepuram, Tamil Nadu ..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 in impugned assessment order on the file of the respondent u/s 73 Act/GST DRC-07 Ref.No. ZD331025362964C / FY 2021-2022 dated 30.10.2025 for the assessment year 2021-2022, and quash the same as illegal and devoid of merits. For Petitioner(s): Mr.S.Naresh Kumar For Respondent(s): Ms.Amirta Poonkodi Dinakaran, Government Counsel (Tax) ************ __________ Page1 of 4 https://www.mhc.tn.gov.in/judis WP No. 23706 of 2026 ORDER An order dated 30.10.2025 is assailed on the ground that the petitioner did not have a reasonable opportunity to contest the tax demand on merits. 2. Ms.Amirta Poonkodi Dinakaran, 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 25% 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 25% of the disputed tax demand 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. __________ Page2 of 4 https://www.mhc.tn.gov.in/judis WP No. 23706 of 2026 6. The writ petition is disposed of on the above terms. Consequently, connected writ miscellaneous petitions are closed. There shall be no order as to costs. 02-07-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To The Assistant Commissioner Ambattur Industrial Estate, Ambattur, Kancheepuram, Tamil Nadu __________ Page3 of 4 https://www.mhc.tn.gov.in/judis WP No. 23706 of 2026 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 23706 of 2026 and W.M.P.Nos.25678 & 25679 of 2026 02-07-2026 __________ Page4 of 4 https://www.mhc.tn.gov.in/judis

WP No. 23706 of 2026 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 02-07-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 23706 of 2026 and W.M.P.Nos.25678 & 25679 of 2026 Shree Shyambaba Container Service Rep. by its Proprietor HANUMAN PILANIA S/o. Satbir Singh, No.17, Umapathy Complex, Shanmuga Nagar Salai, Puranagar Backside, Switha Dental college, Chennai, Tamil Nadu 600077 ..Petitioner(s) Vs The Assistant Commissioner Ambattur Industrial Estate, Ambattur, Kancheepuram, Tamil Nadu ..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 in impugned assessment order on the file of the respondent u/s 73 Act/GST DRC-07 Ref.No. ZD331025362964C / FY 2021-2022 dated 30.10.2025 for the assessment year 2021-2022, and quash the same as illegal and devoid of merits. For Petitioner(s): Mr.S.Naresh Kumar For Respondent(s): Ms.Amirta Poonkodi Dinakaran, Government Counsel (Tax) ************ __________ Page1 of 4 https://www.mhc.tn.gov.in/judis WP No. 23706 of 2026 ORDER An order dated 30.10.2025 is assailed on the ground that the petitioner did not have a reasonable opportunity to contest the tax demand on merits. 2. Ms.Amirta Poonkodi Dinakaran, 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 25% 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 25% of the disputed tax demand 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. __________ Page2 of 4 https://www.mhc.tn.gov.in/judis WP No. 23706 of 2026 6. The writ petition is disposed of on the above terms. Consequently, connected writ miscellaneous petitions are closed. There shall be no order as to costs. 02-07-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To The Assistant Commissioner Ambattur Industrial Estate, Ambattur, Kancheepuram, Tamil Nadu __________ Page3 of 4 https://www.mhc.tn.gov.in/judis WP No. 23706 of 2026 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 23706 of 2026 and W.M.P.Nos.25678 & 25679 of 2026 02-07-2026 __________ Page4 of 4 https://www.mhc.tn.gov.in/judis