WP No. 26481 of 2026 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 22-07-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 26481 of 2026 and W.M.P.Nos.28967 & 28968 of 2026 SMS Infrastructure Rep by its Proprietor V.Prabakar, Plot No. 31-A, Sipcot Industrial Complex, Phase II, Moranapalli Village, Hosur-635109. ..Petitioner(s) Vs The Deputy State Tax Officer- 2 Hosur (North-2) Assessment Circle, Survey No.773, Anna Centenary Building, Ground Floor, Integrated Commercial Taxes Offices Buildings, Seetharammedu, Hosur- 635 109. ..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 of the Respondent Order dated 20.02.2025 with Reference No. ZD330225209165T pertaining to the Financial Year 2020-21 and quash the same. For Petitioner(s): Ms.H.Krithika for Mr.Adithya Reddy For Respondent(s): Mr.R.Sethu Prabakaran, Government Counsel (Tax) **************** __________ Page1 of 4 https://www.mhc.tn.gov.in/judis WP No. 26481 of 2026 ORDER An order dated 20.02.2025 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. 26481 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. 22-07-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To The Deputy State Tax Officer- 2 Hosur (North-2) Assessment Circle, Survey No.773, Anna Centenary Building, Ground Floor, Integrated Commercial Taxes Offices Buildings, Seetharammedu, Hosur- 635 109. __________ Page3 of 4 https://www.mhc.tn.gov.in/judis WP No. 26481 of 2026 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 26481 of 2026 and W.M.P.Nos.28967 & 28968 of 2026 22-07-2026

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WP No. 26481 of 2026 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 22-07-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 26481 of 2026 and W.M.P.Nos.28967 & 28968 of 2026 SMS Infrastructure Rep by its Proprietor V.Prabakar, Plot No. 31-A, Sipcot Industrial Complex, Phase II, Moranapalli Village, Hosur-635109. ..Petitioner(s) Vs The Deputy State Tax Officer- 2 Hosur (North-2) Assessment Circle, Survey No.773, Anna Centenary Building, Ground Floor, Integrated Commercial Taxes Offices Buildings, Seetharammedu, Hosur- 635 109. ..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 of the Respondent Order dated 20.02.2025 with Reference No. ZD330225209165T pertaining to the Financial Year 2020-21 and quash the same. For Petitioner(s): Ms.H.Krithika for Mr.Adithya Reddy For Respondent(s): Mr.R.Sethu Prabakaran, Government Counsel (Tax) **************** __________ Page1 of 4 https://www.mhc.tn.gov.in/judis WP No. 26481 of 2026 ORDER An order dated 20.02.2025 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. 26481 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. 22-07-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To The Deputy State Tax Officer- 2 Hosur (North-2) Assessment Circle, Survey No.773, Anna Centenary Building, Ground Floor, Integrated Commercial Taxes Offices Buildings, Seetharammedu, Hosur- 635 109. __________ Page3 of 4 https://www.mhc.tn.gov.in/judis WP No. 26481 of 2026 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 26481 of 2026 and W.M.P.Nos.28967 & 28968 of 2026 22-07-2026

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