WP No. 32090 of 2026 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 20-08-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 32090 of 2026 and W.M.P.Nos.35290 & 35291 of 2026 Tvl S Papers, (Represetned by its Proprietor Srinivasan Sathishkumar) No 42, Anderson street, Chennai 600 001 ..Petitioner(s) Vs The Deputy State Tax Officer-I (Also known as Deputy Commercial Tax officer) Kothawalchavadi assessment Circle, Room no 313, 3rd Floor, Integrated commercial Taxes office complex, No 32 Elephant Gate Bridge Road, Vepery Chennai 600 003 ..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 on the files of the Respondent herein in impugned Assessment Order in GSTN: 33BIVPS0803H1Z4/2021-22 dated 11.12.2025 along with the summary Order in Form GST DRC-07 vide Reference No. ZD331225172381O, and quash the same. For Petitioner(s): Mr.P Dileep Kumar For Respondent(s): Mr.I.Dinesh, Additional Government Pleader (Tax) ******* __________ Page1 of 4 https://www.mhc.tn.gov.in/judis WP No. 32090 of 2026 ORDER An order dated 11.12.2025 is assailed on the ground that the petitioner did not have a reasonable opportunity to contest the tax demand on merits. 2. Mr.I.Dinesh, 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. Learned counsel for the petitioner submits that about 37% of the tax demand was recovered. He relies on the electronic credit ledger. On instructions, he agrees that the petitioner would remit an additional 13% so as to remit 50% in the aggregate as a condition for remand. An endorsement to that effect has been made on the bundle. 5. Subject to verifying and confirming that 37% of the tax demand was recovered earlier and subject further to the remittance of an additional amounts so as to remit 50% of the tax demand in the aggregate within thirty days from the date of receipt of a copy of this order, the impugned order is set aside and __________ Page2 of 4 https://www.mhc.tn.gov.in/judis WP No. 32090 of 2026 the matter is remanded for re-consideration. After providing a reasonable opportunity to the petitioner, a fresh order shall be issued within five months from the date of remittance of 50% in the aggregate 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 State Tax Officer-I

(Also known as Deputy Commercial Tax officer) Kothawalchavadi assessment Circle, Room no 313, 3rd Floor, Integrated commercial Taxes office complex, No 32 Elephant Gate Bridge Road, Vepery Chennai 600 003 __________ Page3 of 4 https://www.mhc.tn.gov.in/judis WP No. 32090 of 2026 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 32090 of 2026 and W.M.P.Nos.35290 & 35291 of 2026 20-08-2026 __________ Page4 of 4 https://www.mhc.tn.gov.in/judis

WP No. 32090 of 2026 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 20-08-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 32090 of 2026 and W.M.P.Nos.35290 & 35291 of 2026 Tvl S Papers, (Represetned by its Proprietor Srinivasan Sathishkumar) No 42, Anderson street, Chennai 600 001 ..Petitioner(s) Vs The Deputy State Tax Officer-I (Also known as Deputy Commercial Tax officer) Kothawalchavadi assessment Circle, Room no 313, 3rd Floor, Integrated commercial Taxes office complex, No 32 Elephant Gate Bridge Road, Vepery Chennai 600 003 ..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 on the files of the Respondent herein in impugned Assessment Order in GSTN: 33BIVPS0803H1Z4/2021-22 dated 11.12.2025 along with the summary Order in Form GST DRC-07 vide Reference No. ZD331225172381O, and quash the same. For Petitioner(s): Mr.P Dileep Kumar For Respondent(s): Mr.I.Dinesh, Additional Government Pleader (Tax) ******* __________ Page1 of 4 https://www.mhc.tn.gov.in/judis WP No. 32090 of 2026 ORDER An order dated 11.12.2025 is assailed on the ground that the petitioner did not have a reasonable opportunity to contest the tax demand on merits. 2. Mr.I.Dinesh, 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. Learned counsel for the petitioner submits that about 37% of the tax demand was recovered. He relies on the electronic credit ledger. On instructions, he agrees that the petitioner would remit an additional 13% so as to remit 50% in the aggregate as a condition for remand. An endorsement to that effect has been made on the bundle. 5. Subject to verifying and confirming that 37% of the tax demand was recovered earlier and subject further to the remittance of an additional amounts so as to remit 50% of the tax demand in the aggregate within thirty days from the date of receipt of a copy of this order, the impugned order is set aside and __________ Page2 of 4 https://www.mhc.tn.gov.in/judis WP No. 32090 of 2026 the matter is remanded for re-consideration. After providing a reasonable opportunity to the petitioner, a fresh order shall be issued within five months from the date of remittance of 50% in the aggregate 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 State Tax Officer-I

(Also known as Deputy Commercial Tax officer) Kothawalchavadi assessment Circle, Room no 313, 3rd Floor, Integrated commercial Taxes office complex, No 32 Elephant Gate Bridge Road, Vepery Chennai 600 003 __________ Page3 of 4 https://www.mhc.tn.gov.in/judis WP No. 32090 of 2026 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 32090 of 2026 and W.M.P.Nos.35290 & 35291 of 2026 20-08-2026 __________ Page4 of 4 https://www.mhc.tn.gov.in/judis