WP No. 29152 of 2026 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 06-08-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 29152 of 2026 and W.M.P.No.31999 of 2026 M/s.Hemant Roadways India Private Limited Rep. By its Director Mr. Mangal Singh, 860, E, Kauppa Kadu, Sri Sakthi Refineries Compound, Sadayappa Road, Karungalpalayam, Erode, Tamil Nadu-638 003 ..Petitioner(s) Vs The State Tax officer park Road, Assessment circle Erode, Tamilnadu ..Respondent(s) PRAYER: Writ Petition filed under Article 226 of The Constitution of India praying for the issuance of a Writ of Certiorari, call for the records of the Impugned Assessment Order in Ref. No. ZD331225395400N dated 23.12.2025 under Section 73 of the CGST/TNGST Act, 2017 and uploaded the same along with the summary of order in DRC07 dated 26.12.2025 for the Financial Year 2021-22 from the files of the respondent herein, QUASH the same. For Petitioner(s): Ms.Jyotsna Sivakumar for Ms.Aparna Nandakumar For Respondent(s): Ms.G.Dhana Madhri, Special Government Pleader (Tax) ********** __________ Page1 of 4 https://www.mhc.tn.gov.in/judis WP No. 29152 of 2026 ORDER An order dated 23.12.2025 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 Special Government Pleader (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 __________ Page2 of 4 https://www.mhc.tn.gov.in/judis WP No. 29152 of 2026 tax demand. Subject to fulfilment of the above condition, the bank attachment relating to the impugned order shall stand raised. 6. The writ petition is disposed of on the above terms. There shall be no order as to costs. Consequently, the connected writ miscellaneous petition is closed. 06-08-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To The State Tax officer park Road, Assessment circle Erode, Tamilnadu __________ Page3 of 4 https://www.mhc.tn.gov.in/judis WP No. 29152 of 2026 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 29152 of 2026 and W.M.P.No.31999 of 2026 06-08-2026 __________ Page4 of 4

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WP No. 29152 of 2026 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 06-08-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 29152 of 2026 and W.M.P.No.31999 of 2026 M/s.Hemant Roadways India Private Limited Rep. By its Director Mr. Mangal Singh, 860, E, Kauppa Kadu, Sri Sakthi Refineries Compound, Sadayappa Road, Karungalpalayam, Erode, Tamil Nadu-638 003 ..Petitioner(s) Vs The State Tax officer park Road, Assessment circle Erode, Tamilnadu ..Respondent(s) PRAYER: Writ Petition filed under Article 226 of The Constitution of India praying for the issuance of a Writ of Certiorari, call for the records of the Impugned Assessment Order in Ref. No. ZD331225395400N dated 23.12.2025 under Section 73 of the CGST/TNGST Act, 2017 and uploaded the same along with the summary of order in DRC07 dated 26.12.2025 for the Financial Year 2021-22 from the files of the respondent herein, QUASH the same. For Petitioner(s): Ms.Jyotsna Sivakumar for Ms.Aparna Nandakumar For Respondent(s): Ms.G.Dhana Madhri, Special Government Pleader (Tax) ********** __________ Page1 of 4 https://www.mhc.tn.gov.in/judis WP No. 29152 of 2026 ORDER An order dated 23.12.2025 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 Special Government Pleader (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 __________ Page2 of 4 https://www.mhc.tn.gov.in/judis WP No. 29152 of 2026 tax demand. Subject to fulfilment of the above condition, the bank attachment relating to the impugned order shall stand raised. 6. The writ petition is disposed of on the above terms. There shall be no order as to costs. Consequently, the connected writ miscellaneous petition is closed. 06-08-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To The State Tax officer park Road, Assessment circle Erode, Tamilnadu __________ Page3 of 4 https://www.mhc.tn.gov.in/judis WP No. 29152 of 2026 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 29152 of 2026 and W.M.P.No.31999 of 2026 06-08-2026 __________ Page4 of 4

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