W.P.(MD) No.19596 of 2026 BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT DATED: 13.07.2026 CORAM: THE HONOURABLE MR.JUSTICE C.SARAVANAN W.P.(MD) No.19596 of 2026 and W.M.P(MD)No.14503 of 2026 Muhamed Ibrahim, S/o.Muhamed Abdul Kathar, No.7/143, Muslim North Street, Thalaiyuthu, Sankarnagar, Tirunelveli. ... Petitioner - Vs. - The Deputy State Tax Officer-2, Tirunelveli Junction Assessment Circle, Tirunelveli. .. Respondent Prayer : Writ Petition is filed under Article 226 of the Constitution of India, praying this court to issue a Writ of Certiorari calling for the records relating to the impugned order passed by the respondent in his proceedings in GSTIN 33BKEPM5213J1ZC/2021-22 dated 16.12.2025 and quash the same as unconstitutional. 1/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No.19596 of 2026 For Petitioner : Mr.J.K.Jayaseelan For Respondent : Mr.S.Venkatesh Counsel for the State of Tamil Nadu ORDER Heard Mr.J.K.Jayaseelan, learned counsel for the petitioner and Mr.S.Venkatesh, learned counsel for the State of Tamil Nadu, for the respondent. 2.This Writ Petition is disposed of at the time of admission with the consent of the learned counsel for the petitioner and the learned counsel for the State of Tamil Nadu for the respondent. 3.This writ petition has been filed challenging the impugned assessment order passed by the respondent in GSTIN:

33BKEPM5213J1ZC/2021-22 dated 16.12.2025 and in summary order bearing Ref No.ZD331225256372M, dated 16.12.2025 which was preceded by a show cause notice in Form GST DRC-01 dated 23.09.2025, wherein the petitioner was called upon to file a reply along with documentary evidences 2/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No.19596 of 2026 within a period of 30 days from the date of receipt of such notice, and for a direction to the respondent to re-do the assessment proceeding for the year 2021-22. 4. The petitioner was also issued with reminders on 27.10.2025, 13.11.2025 and 02.12.2025, which called upon the petitioner to file a reply and to appear for a personal hearing. The petitioner appeared for personal hearing. The petitioner, however, neither filed any reply nor provided any reason for the delay in filing the reply. Thus, the impugned order has been passed. 5. When the matter is taken up for hearing today, the learned counsel for the petitioner submits that the petitioner is willing to pre-deposit 10% of the disputed tax as a condition for de novo adjudication and has also made an endorsement to that effect in the Court Bundle, which reads as under:-“Writ petitioner undertakes to pay 10% of the disputed tax.” 6. Recording the same, the case is remitted back to the respondent to pass a fresh order subject to the petitioner depositing 10% of the disputed tax 3/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No.19596 of 2026

in cash from the petitioner's electronic cash register within a period of thirty days from the date of receipt of a copy of this order. 7. Within such time, the petitioner shall also file a reply to the show cause notice in Form GST DRC-01 dated 23.09.2025 together with requisite documents to substantiate the case by treating the impugned order dated 16.12.2025 as an addendum to the show cause notice dated 23.09.2025. 8.In case, the petitioner complies with the above stipulations, the respondent shall proceed to pass a final order on merits and in accordance with law as expeditiously as possible, preferably, within a period of three months of such reply/pre-deposit. Subject to the petitioner complying with the above stipulations, the attachment of the bank account of the petitioner, if any, shall also stand automatically vacated. 9.It is made clear that the bank attachment shall be lifted subject to the deposit of 10% of the disputed tax as ordered above and the petitioner not being in arrears of any other amount for any other tax period barring the amount demanded under the impugned order. 4/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No.19596 of 2026

10.In case the petitioner fails to comply with any of the stipulations, the respondent is at liberty to proceed against the petitioner to recover the tax in accordance with law as if this writ petition was dismissed in limine today. 11.Needless to state, before passing any such order, the respondent shall issue due notice on the petitioner. 12.This Writ Petition stands disposed of with the above observations. No costs. Consequently, connected Miscellaneous Petition is closed. 13.07.2026 Index : Yes / No NCC : Yes/No PJL To The Deputy State Tax Officer-2, Tirunelveli Junction Assessment Circle, Tirunelveli. 5/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No.19596 of 2026 C.SARAVANAN, J. PJL W.P.(MD) No.19596 of 2026 13.07.2026 6/6 https://www.mhc.tn.gov.in/judis

W.P.(MD) No.19596 of 2026 BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT DATED: 13.07.2026 CORAM: THE HONOURABLE MR.JUSTICE C.SARAVANAN W.P.(MD) No.19596 of 2026 and W.M.P(MD)No.14503 of 2026 Muhamed Ibrahim, S/o.Muhamed Abdul Kathar, No.7/143, Muslim North Street, Thalaiyuthu, Sankarnagar, Tirunelveli. ... Petitioner - Vs. - The Deputy State Tax Officer-2, Tirunelveli Junction Assessment Circle, Tirunelveli. .. Respondent Prayer : Writ Petition is filed under Article 226 of the Constitution of India, praying this court to issue a Writ of Certiorari calling for the records relating to the impugned order passed by the respondent in his proceedings in GSTIN 33BKEPM5213J1ZC/2021-22 dated 16.12.2025 and quash the same as unconstitutional. 1/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No.19596 of 2026 For Petitioner : Mr.J.K.Jayaseelan For Respondent : Mr.S.Venkatesh Counsel for the State of Tamil Nadu ORDER Heard Mr.J.K.Jayaseelan, learned counsel for the petitioner and Mr.S.Venkatesh, learned counsel for the State of Tamil Nadu, for the respondent. 2.This Writ Petition is disposed of at the time of admission with the consent of the learned counsel for the petitioner and the learned counsel for the State of Tamil Nadu for the respondent. 3.This writ petition has been filed challenging the impugned assessment order passed by the respondent in GSTIN:

33BKEPM5213J1ZC/2021-22 dated 16.12.2025 and in summary order bearing Ref No.ZD331225256372M, dated 16.12.2025 which was preceded by a show cause notice in Form GST DRC-01 dated 23.09.2025, wherein the petitioner was called upon to file a reply along with documentary evidences 2/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No.19596 of 2026 within a period of 30 days from the date of receipt of such notice, and for a direction to the respondent to re-do the assessment proceeding for the year 2021-22. 4. The petitioner was also issued with reminders on 27.10.2025, 13.11.2025 and 02.12.2025, which called upon the petitioner to file a reply and to appear for a personal hearing. The petitioner appeared for personal hearing. The petitioner, however, neither filed any reply nor provided any reason for the delay in filing the reply. Thus, the impugned order has been passed. 5. When the matter is taken up for hearing today, the learned counsel for the petitioner submits that the petitioner is willing to pre-deposit 10% of the disputed tax as a condition for de novo adjudication and has also made an endorsement to that effect in the Court Bundle, which reads as under:-“Writ petitioner undertakes to pay 10% of the disputed tax.” 6. Recording the same, the case is remitted back to the respondent to pass a fresh order subject to the petitioner depositing 10% of the disputed tax 3/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No.19596 of 2026

in cash from the petitioner's electronic cash register within a period of thirty days from the date of receipt of a copy of this order. 7. Within such time, the petitioner shall also file a reply to the show cause notice in Form GST DRC-01 dated 23.09.2025 together with requisite documents to substantiate the case by treating the impugned order dated 16.12.2025 as an addendum to the show cause notice dated 23.09.2025. 8.In case, the petitioner complies with the above stipulations, the respondent shall proceed to pass a final order on merits and in accordance with law as expeditiously as possible, preferably, within a period of three months of such reply/pre-deposit. Subject to the petitioner complying with the above stipulations, the attachment of the bank account of the petitioner, if any, shall also stand automatically vacated. 9.It is made clear that the bank attachment shall be lifted subject to the deposit of 10% of the disputed tax as ordered above and the petitioner not being in arrears of any other amount for any other tax period barring the amount demanded under the impugned order. 4/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No.19596 of 2026

10.In case the petitioner fails to comply with any of the stipulations, the respondent is at liberty to proceed against the petitioner to recover the tax in accordance with law as if this writ petition was dismissed in limine today. 11.Needless to state, before passing any such order, the respondent shall issue due notice on the petitioner. 12.This Writ Petition stands disposed of with the above observations. No costs. Consequently, connected Miscellaneous Petition is closed. 13.07.2026 Index : Yes / No NCC : Yes/No PJL To The Deputy State Tax Officer-2, Tirunelveli Junction Assessment Circle, Tirunelveli. 5/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No.19596 of 2026 C.SARAVANAN, J. PJL W.P.(MD) No.19596 of 2026 13.07.2026 6/6 https://www.mhc.tn.gov.in/judis