Madras High Court
WP/37068/2026 of Tvl LLSS Fire Solutions Private Limited Vs The state Tax officer/commercial tax officer on 23 September 2026
WP No. 37068 of 2026
IN THE HIGH COURT OF JUDICATURE AT MADRAS
DATED: 23-09-2026
CORAM
THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY
WP No. 37068 of 2026
and W.M.P.Nos.41592 & 41595 of 2026
CNR: {HCMA012108972026}
Tvl LLSS Fire Solutions Private Limited
Rep by its director-R.Dinesh,
D.No.750, Palaiyur Black Mariamman Koil Street, Pappanaickenpalayam, Coimbatore 641 037.
GSTIN 33AADCL1605L1ZR
..Petitioner(s)
Vs
The state Tax officer/commercial tax officer Office of the Commercial Tax officer P.N.Palayam Assessment circle, Coimbatore
..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 of the impugned proceedings of the Respondent in GSTIN
33AADCL1605L1ZR/2021-22 dated 11.12.2025 along with its consequential impugned Summary Order vide Form GST DRC-07 in Reference No.
ZD331225171072U dated 11.12.2025 for the Tax Period April 2021 March 2022, quash the same.
For Petitioner(s):
Mr.Kowsickvel.S
WP No. 37068 of 2026
For Respondent(s):
Mr.I.Dinesh,
Additional Government Pleader (Tax)
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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 10% of the tax demand relating to CGST and about 16% of the tax demand relating to SGST was recovered. Subject to giving credit thereto, he submits that additional amount should be remitted so as to remit 25% of the tax demand in the aggregate. An endorsement to that effect has been made on the bundle.
WP No. 37068 of 2026
5. Subject to verifying and confirming the recoveries made earlier and subject further to the remittance of additional amounts so as to remit 25% of the tax demand under the impugned order in the aggregate within thirty days from the date of receipt of a copy of this order, the impugned order is set aside so as to provide an opportunity to the petitioner to contest the tax proposals on merits and 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 25% of the tax demand in the aggregate. Subject to fulfilment of this condition, the bank attachment if any, relating to the impugned order shall be 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. 23-09-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To The state Tax officer/commercial tax officer Office of the Commercial Tax officer P.N.Palayam Assessment circle Coimbatore
WP No. 37068 of 2026
SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 37068 of 2026 and W.M.P.Nos.41592 & 41595 of 2026 23-09-2026