WP No. 25029 of 2026 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 13-07-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 25029 of 2026 and W.M.P.Nos.27317, 27319 & 27321 of 2026 Udhayarani Sarees Rep by, Mrs. Santha Ramakrishna Proprietor, No. 65, Narasingapuram Street, Gugai, Salem 636 006 ..Petitioner(s) Vs 1. The Appellate Authority The Deputy Commissioner (CT) Salem District 2. The Assistant Commissioner ST Gugai, Salem - 1 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 2nd Respondent’s order dated 15.09.2025 pertinent to the assessment year (2021-2022) in GSTIN number (33AAVPR3978B1Z9) which subsequently culminated in the Appeal Rejection order dated 27.02.2026 passed by the 1st Respondent in FORM GST APL 02 pertinent to the assessment year 2021 - 2022 in GSTIN number (33AAVPR3978B1Z9) and quash the same and consequently direct the 2nd Respondent to pass the fresh assessment order. __________ Page1 of 4 https://www.mhc.tn.gov.in/judis WP No. 25029 of 2026 For Petitioner(s): Mr.V.G. Vijayraj For Respondent(s): Ms.G.Dhana Madhri, Government Counsel (Tax) ************** ORDER An order dated 15.09.2025 is assailed on the ground that the petitioner did not have a reasonable opportunity to contest the tax demand on merits.

2. Ms.G.Dhana Madhri, 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. Learned counsel for the petitioner submits that 10% pre-deposit was made while filing the statutory appeal. He submits that the petitioner agrees to remit an additional 15% of the disputed tax demand as a condition for remand. An endorsement to that effect has been made on the bundle. __________ Page2 of 4 https://www.mhc.tn.gov.in/judis WP No. 25029 of 2026 5. Subject to the remittance of an additional 15% of the disputed tax demand by the petitioner within thirty days from the date of receipt of a copy of this order, the order in original 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 an additional 15% of the disputed tax demand by the petitioner. 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. 13-07-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To 1. The Appellate Authority The Deputy Commissioner (CT) Salem District 2. The Assistant Commissioner ST

Gugai, Salem - 1 Circle, Salem District __________ Page3 of 4 https://www.mhc.tn.gov.in/judis WP No. 25029 of 2026 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 25029 of 2026 and W.M.P.Nos.27317, 27319 & 27321 of 2026 13-07-2026 __________ Page4 of 4 https://www.mhc.tn.gov.in/judis

WP No. 25029 of 2026 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 13-07-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 25029 of 2026 and W.M.P.Nos.27317, 27319 & 27321 of 2026 Udhayarani Sarees Rep by, Mrs. Santha Ramakrishna Proprietor, No. 65, Narasingapuram Street, Gugai, Salem 636 006 ..Petitioner(s) Vs 1. The Appellate Authority The Deputy Commissioner (CT) Salem District 2. The Assistant Commissioner ST Gugai, Salem - 1 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 2nd Respondent’s order dated 15.09.2025 pertinent to the assessment year (2021-2022) in GSTIN number (33AAVPR3978B1Z9) which subsequently culminated in the Appeal Rejection order dated 27.02.2026 passed by the 1st Respondent in FORM GST APL 02 pertinent to the assessment year 2021 - 2022 in GSTIN number (33AAVPR3978B1Z9) and quash the same and consequently direct the 2nd Respondent to pass the fresh assessment order. __________ Page1 of 4 https://www.mhc.tn.gov.in/judis WP No. 25029 of 2026 For Petitioner(s): Mr.V.G. Vijayraj For Respondent(s): Ms.G.Dhana Madhri, Government Counsel (Tax) ************** ORDER An order dated 15.09.2025 is assailed on the ground that the petitioner did not have a reasonable opportunity to contest the tax demand on merits.

2. Ms.G.Dhana Madhri, 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. Learned counsel for the petitioner submits that 10% pre-deposit was made while filing the statutory appeal. He submits that the petitioner agrees to remit an additional 15% of the disputed tax demand as a condition for remand. An endorsement to that effect has been made on the bundle. __________ Page2 of 4 https://www.mhc.tn.gov.in/judis WP No. 25029 of 2026 5. Subject to the remittance of an additional 15% of the disputed tax demand by the petitioner within thirty days from the date of receipt of a copy of this order, the order in original 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 an additional 15% of the disputed tax demand by the petitioner. 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. 13-07-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To 1. The Appellate Authority The Deputy Commissioner (CT) Salem District 2. The Assistant Commissioner ST

Gugai, Salem - 1 Circle, Salem District __________ Page3 of 4 https://www.mhc.tn.gov.in/judis WP No. 25029 of 2026 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 25029 of 2026 and W.M.P.Nos.27317, 27319 & 27321 of 2026 13-07-2026 __________ Page4 of 4 https://www.mhc.tn.gov.in/judis