WP No. 24631 of 2026 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 09-07-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 24631 of 2026 and W.M.P.Nos.26862 & 26864 of 2026 Sri Guperalakshmi Tex Rep by, J. Raveendran Proprietor No. 102/34-A, Rangadas Street, Jari Kondalampatti, Salem - 636010. ..Petitioner(s) Vs The Assistant Commissioner (ST) Kondalampatty, salem-I Assessment Circle, salem District. ..Respondent(s) PRAYER: Writ Petition filed under Article 226 of The Constitution of India praying for the issuance of a Writ of Certiorarified Mandamus, calling for the records of the Respondent’s order dated 06.11.2025, pertinent to the assessment year 2021 - 2022 in GSTIN number 33ANQPR3231F1Z1 and quash the same and consequently direct the Respondent to pass the fresh assessment order. For Petitioner(s): Mr.K.Narayanan For Respondent(s): Mr.R.Sethu Prabakaran, Government Counsel (Tax) ********** __________ Page1 of 4 https://www.mhc.tn.gov.in/judis WP No. 24631 of 2026 ORDER An order dated 06.11.2025 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 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. 24631 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. 09-07-2026 (1/3) Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To The Assistant Commissioner (ST) Kondalampatty, salem-I Assessment Circle, salem District. __________ Page3 of 4 https://www.mhc.tn.gov.in/judis WP No. 24631 of 2026 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 24631 of 2026 and W.M.P.Nos.26862 & 26864 of 2026 09-07-2026 (1/3) __________ Page4 of 4 https://www.mhc.tn.gov.in/judis

WP No. 24631 of 2026 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 09-07-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 24631 of 2026 and W.M.P.Nos.26862 & 26864 of 2026 Sri Guperalakshmi Tex Rep by, J. Raveendran Proprietor No. 102/34-A, Rangadas Street, Jari Kondalampatti, Salem - 636010. ..Petitioner(s) Vs The Assistant Commissioner (ST) Kondalampatty, salem-I Assessment Circle, salem District. ..Respondent(s) PRAYER: Writ Petition filed under Article 226 of The Constitution of India praying for the issuance of a Writ of Certiorarified Mandamus, calling for the records of the Respondent’s order dated 06.11.2025, pertinent to the assessment year 2021 - 2022 in GSTIN number 33ANQPR3231F1Z1 and quash the same and consequently direct the Respondent to pass the fresh assessment order. For Petitioner(s): Mr.K.Narayanan For Respondent(s): Mr.R.Sethu Prabakaran, Government Counsel (Tax) ********** __________ Page1 of 4 https://www.mhc.tn.gov.in/judis WP No. 24631 of 2026 ORDER An order dated 06.11.2025 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 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. 24631 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. 09-07-2026 (1/3) Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To The Assistant Commissioner (ST) Kondalampatty, salem-I Assessment Circle, salem District. __________ Page3 of 4 https://www.mhc.tn.gov.in/judis WP No. 24631 of 2026 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 24631 of 2026 and W.M.P.Nos.26862 & 26864 of 2026 09-07-2026 (1/3) __________ Page4 of 4 https://www.mhc.tn.gov.in/judis