WP/39146/2026 of RTS Systems Vs The Deputy State Tax Officer (ST) on 6 October 2026

ORDER

This writ petition has been filed against the impugned assessment order dated 26.02.2025 passed by the respondent.

WP No. 39146 of 2026

2. Mr.I.Dinesh, learned Additional Government Pleader, takes notice on behalf of the respondent. By consent of the parties, the main writ petition is taken up for disposal at the admission stage itself.

3. The learned counsel for the petitioner would submit that in this case, a show cause notice was issued by the respondent on 26.11.2024, for which, the petitioner had filed their reply on 21.12.2024. Thereafter, the assessment order came to be passed by the respondent on 26.02.2025. Aggrieved over the said impugned order, a rectification application was filed by the petitioner on 27.11.2025, however, the same was rejected vide the order dated 11.02.2026. He would contend that the reply filed by the petitioner was not considered by the respondent in the proper manner and also no opportunity of personal hearing was granted to the petitioner while passing the impugned assessment order, which is a clear violation of principles of natural justice. Hence, he requests this Court to set aside the assessment order passed by the respondent.

4. On the other hand, the learned Additional Government Pleader appearing for the respondent would submit that in this case, after the receipt of show case notice, the petitioner had filed their reply dated 21.12.2024 and on considering the reply only the impugned order came to be passed.

5. Further, he would submit that now, the only recourse available to the petitioner is to file an appeal against the impugned assessment order. Hence, he requests this Court for dismissal of this petition.

WP No. 39146 of 2026

6. In reply, the learned counsel for the petitioner would submit that now, the petitioner is willing to file an appeal against the said impugned assessment order. He also submits that the petitioner had already paid the 20% of the disputed tax amount to the respondent (10% of disputed tax amount towards statutory pre-deposit for filing the appeal along with additional 10% of disputed tax amount.

7. Heard the learned counsel for the petitioner and the learned Additional Government Pleader appearing for the respondent and also perused the entire materials on record.

8. In the case on hand, the impugned order came to be passed after considering the reply submitted by the petitioner. According to the petitioner, the reply filed by the petitioner was not considered and no opportunity of personal hearing was provided to the petitioner while passing the assessment order.

9. In such view of the matter, the only recourse available to the petitioner is to file an appeal against the impugned order.

10. Accordingly, this writ petition is dismissed by granting liberty to the petitioner to file an appeal before the concerned Appellate Authority, within a period of two weeks from the date of receipt of copy of this order, subject to the payment of cost of Rs.2000/- to the Tamil Nadu Legal Aid Service Authority within a period of two weeks. Upon production of proof for such payment, the

WP No. 39146 of 2026

Appellate Authority shall consider the said appeal filed by the petitioner on its own merits and in accordance with law, by providing sufficient opportunity to the petitioner, without pressing for limitation.

11. Further, the respondent is directed to instruct the concerned Bank to lift the attachment and to de-freeze the bank account of the petitioner, immediately upon the production of proof with regard to the payment made by the petitioner as stated above. Consequently, the connected miscellaneous petitions are also closed. 06-10-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No ssk To The Deputy State Tax Officer (ST), Arumbakkam Assessment Circle, No.1 Greams Road, 4th Floor, PAPJM Annexure Building, Chennai- 600 006.

WP No. 39146 of 2026

KRISHNAN RAMASAMY, J. ssk WP No. 39146 of 2026 06-10-2026