WP No. 32068 of 2026 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 20-08-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 32068 of 2026 and W.M.P.Nos.35275 & 35280 of 2026 M/s MSE Industries Represented by its Managing Partner, K.B. Maheshkumar, No. 57B, Anamalai Amman Kovil Street, L and T Bypass Road, Vellalore, Coimbatore-641111. ..Petitioner(s) Vs The Deputy Commercial Tax Officer, Podanur Assessment Circle, Coimbatore 641111. ..Respondent(s) PRAYER: Writ Petition filed under Article 226 of The Constitution of India praying for the issuance of a Writ of Certiorari, to call for the records pertaining to the impugned order issued vide FORM DRC-07 in Ref. No. ZD331225302765M dated 19.12.2025 for the assessment year 2018 - 2019, by the respondent and quash the same. For Petitioner(s): Mr.Derrick Sam For Respondent(s): Ms.Amirta Poonkodi Dinakaran, Additional Government Pleader (Tax) ******** __________ Page1 of 4 https://www.mhc.tn.gov.in/judis WP No. 32068 of 2026 ORDER An order dated 19.12.2025 is assailed on the ground that the petitioner did not have a reasonable opportunity to contest the tax demand on merits. 2. Ms.Amirta Poonkodi Dinakaran, learned Additional 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. 32068 of 2026 tax demand. Subject to the above condition, the petitioner’s bank attachment relating to the impugned order shall stand raised. 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. 20-08-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To The Deputy Commercial Tax Officer, Podanur Assessment Circle, Coimbatore 641111. __________ Page3 of 4 https://www.mhc.tn.gov.in/judis WP No. 32068 of 2026 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 32068 of 2026 and W.M.P.Nos.35275 & 35280 of 2026 20-08-2026 __________ Page4 of 4 https://www.mhc.tn.gov.in/judis

WP No. 32068 of 2026 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 20-08-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 32068 of 2026 and W.M.P.Nos.35275 & 35280 of 2026 M/s MSE Industries Represented by its Managing Partner, K.B. Maheshkumar, No. 57B, Anamalai Amman Kovil Street, L and T Bypass Road, Vellalore, Coimbatore-641111. ..Petitioner(s) Vs The Deputy Commercial Tax Officer, Podanur Assessment Circle, Coimbatore 641111. ..Respondent(s) PRAYER: Writ Petition filed under Article 226 of The Constitution of India praying for the issuance of a Writ of Certiorari, to call for the records pertaining to the impugned order issued vide FORM DRC-07 in Ref. No. ZD331225302765M dated 19.12.2025 for the assessment year 2018 - 2019, by the respondent and quash the same. For Petitioner(s): Mr.Derrick Sam For Respondent(s): Ms.Amirta Poonkodi Dinakaran, Additional Government Pleader (Tax) ******** __________ Page1 of 4 https://www.mhc.tn.gov.in/judis WP No. 32068 of 2026 ORDER An order dated 19.12.2025 is assailed on the ground that the petitioner did not have a reasonable opportunity to contest the tax demand on merits. 2. Ms.Amirta Poonkodi Dinakaran, learned Additional 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. 32068 of 2026 tax demand. Subject to the above condition, the petitioner’s bank attachment relating to the impugned order shall stand raised. 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. 20-08-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To The Deputy Commercial Tax Officer, Podanur Assessment Circle, Coimbatore 641111. __________ Page3 of 4 https://www.mhc.tn.gov.in/judis WP No. 32068 of 2026 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 32068 of 2026 and W.M.P.Nos.35275 & 35280 of 2026 20-08-2026 __________ Page4 of 4 https://www.mhc.tn.gov.in/judis