Madras High Court
WP/38575/2026 of SRI LAKSHMI SARASWATHI IMPEEX INDIA LIMITED Vs STATE TAX OFFICER on 6 October 2026
IN THE HIGH COURT OF JUDICATURE AT MADRAS
DATED: 06-10-2026
CORAM
THE HON'BLE MR JUSTICE KRISHNAN RAMASAMY
WP Nos. 38575, 38588, 38590 & 38592 of 2026
CNR:{HCMA012009742026}
AND WMP NO. 43257, 43281, 43288 & 43284 OF 2026
Sri Lakshmi Saraswathi Impeex India Limited GSTN.33AAFCS5464C1ZK
Rep by G. Nithyananthan
No9, Old No.8, Crescent Road,
Shenoy Nagar, Chennai 600030
..Petitioner(s) in all
petitions
Vs
State Tax Officer,
Group I, Intelligence I, No.1,
PAPJM Buildings, Greams Road,
Thousand Lights, Chennai 6
..Respondent(s) in all
petitions
Common Prayer:
Writ Petition filed under Article 226 of the Constitution of India, praying for issuance of Writ of Certiorari, calling upon the records of the impugned order issued by the Respondent in Form GST DRC-07 bearing Reference No.ZD3303262578570 dated 27.03.2026 along with attachment to DRC 07 dated 27.03.2026 for the AY
2023-24, quash the same and consequently remand the matter to the Respondent directing them to to entertain the records, documents and reply from the Petitioner and then pass an order on affording a personal hearing to the calling upon the records of the impugned order issued by the Respondent in Form GST DRC-07 bearing Reference No.ZD3303262578273
dated 27.03.2026 along with attachment to DRC 07 dated 27.03.2026 for the AY 2020-21, quash the same and consequently remand the matter to the Respondent directing them to entertain the records, documents and reply from the Petitioner and then pass an order on affording a personal hearing to the
Petitioner herein
calling upon the records of the impugned order issued by the Respondent in Form GST DRC-07 bearing Reference No.ZD3303262578790
dated 27.03.2026 for the AY 2021-22 along with attachment to DRC 07 dated 27.03.2026, quash the same and consequently remand the matter to the Respondent directing them to entertain the records, documents and reply from the Petitioner and then pass an order on affording a personal hearing to the
calling upon the records of the impugned order issued by the Respondent in Form GST DRC-07 bearing Reference No.ZD330326257913A dated 27.03.2026 along with attachment to DRC 07 dated 27.03.2026 for the AY
2022-23, quash the same and consequently remand the matter to the Respondent directing them to entertain the records, documents and reply from the Petitioner and then pass an order on affording a personal hearing to the
For Petitioner(s):
Mr.Tharun Pranav
For Respondent(s):
Ms.G.Dhana Madhri, SGP
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Common Order
These writ petitions have been filed challenging the orders dated 27.03.2026 passed by the respondent.
2. Ms.G.Dhana Madhri, learned Special Government Pleader, takes notice on behalf of the respondent.
3. By consent of the parties, the main writ petition is taken up for disposal at the admission stage itself.
4. The learned counsel for the petitioner would submit that in these cases, the personal hearing was scheduled on 24.03.2026 at 11.30 am. However, though the notice for personal hearing was signed by the respondent on 20.03.2026, it received by the petitioner only on 24.03.2026 (very same day on which the personal hearing was scheduled), due to which, they were not in a position to participate in the said personal hearing. Under these circumstances, the impugned orders came to be passed by the respondent without hearing the petitioner, which is in violation of principles of natural justice. Hence, these petitions have been filed.
5. Further, he would submit that the petitioner is ready and willing to pay 5% of the disputed tax amount to the respondent in each petitions. Hence, he requests this Court to grant an opportunity to the petitioner to present their case before the respondent by setting aside the impugned orders.
6. On the other hand, the learned counsel appearing for the respondent would submit that though the notice for personal hearing was sent to the petitioner, by RPAD, as early as on 20.03.2026, the same was received by the petitioner only on 24.03.2026. However, she has fairly admitted that no opportunity of personal hearing was provided to the petitioner prior to the passing of impugned orders. Therefore, she requested this Court to remit the matters back to the respondent on terms.
7. Heard the learned counsel for the petitioner and the respondent and also perused the materials available on record.
8. In the case on hand, though very many issues were raised on the part of the petitioner, the learned counsel had restricted his submissions to the extent of non-providing of an opportunity of personal hearing to the petitioner. Admittedly, though the personal hearing notice was sent by the respondent by way of RPAD as early as on 20.03.2026, the same was received by the petitioner only on 24.03.2026. Since the personal hearing was fixed on 24.03.2026, i.e., the very same day, on which the notice was received by the petitioner, they were not in a position to appear before the respondent. Under these circumstances, the impugned orders came to be passed without providing any opportunity of personal hearing. In such case, it is clear that the said impugned orders are passed in violation of principles of natural justice and the same is not sustainable in law.
11. Further, it was submitted by the learned counsel for the petitioner that the petitioner is ready and willing to pay 5% of the disputed tax amount to the respondent in each petitions. In such view of the matter, this Court is inclined to set aside all the impugned orders dated 27.03.2026 passed by the respondent. Accordingly, this Court passes the following order:-
(i) The impugned orders dated 27.03.2026 are set aside and the matters are remanded to the respondent for fresh consideration on condition that the petitioner shall pay 5% of disputed tax amount to the respondent, in each petitions, within a period of four weeks from the date of receipt of a copy of this order. The setting aside of the impugned orders will take effect from the date of payment of the said amount.
(ii) The petitioner shall file their reply/objection along with the required documents, if any, within a period of three weeks from the date of payment of amount as stated above.
(iii) On filing of such reply/objection by the petitioner, the respondent shall consider the same and issue a 14 days clear notice, by fixing the date of personal hearing, to the petitioner and thereafter, pass appropriate orders on merits and in accordance with law, after hearing the petitioner, as expeditiously as possible.
12. With the above directions, these writ petitions are disposed of. No costs. Consequently, the connected miscellaneous petitions are also closed. 06-10-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No nsa To State Tax Officer, Group III, Chengalpattu Intelligence Division, No.870 / 2A, 1st Floor, Kancheepuram High Road, Thimmavaram, Chengalpattu 603101.
KRISHNAN RAMASAMY J. nsa WP Nos. 38575, 38588, 38590 & 38592 of 2026 06-10-2026 (1/2)