Madras High Court
WP/37819/2026 of M/S.FRIENDS ENTERPRISES Vs THE DEPUTY STATE TAX OFFICER - 2 on 23 September 2026
WP No. 37819 of 2026
IN THE HIGH COURT OF JUDICATURE AT MADRAS
DATED: 23-09-2026
CORAM
THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY
WP No. 37819 of 2026
and WMP.Nos.42467 & 42469 of 2026
CNR: {HCMA011938622026}
M/s. Friends Enterprises,
Rep. by its Proprietor S.Dhamodaran,
B2/99, Main Street, Sengadu Village and Post, Kancheepuram, Tamil Nadu – 602002.
..Petitioner
Vs
The Deputy State Tax Officer - 2
Sriperumbudur Assessment Circle,
office of the Assistant Commissioner (ST), No.4/109, Varadarajapuram, Chennai - Bangalore Highway, Room No.12, ground floor, Chennai - 600123.
..Respondent
Prayer: Writ Petition is filed under Article 226 of the Constitution of India praying for issuance of Writ of Certiorarified Mandamus to call for the entire records of impugned assessment order passed by the respondent herein in GSTIN : 33BVBPD7142M1ZO/2020-21 dated 25.02.2025 vide reference ID:
ZD330225262009O for the financial year 2020-2021, to quash the same and consequently direct the respondent to pass a fresh order after affording opportunity to the petitioner to explain the case and produce supporting documents.
For Petitioner:
Mr. K.B.Hariharan
WP No. 37819 of 2026
For Respondent:
Mr. I. Dinesh
Additional Government Pleader (Tax)
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ORDER
Order dated 25.02.2025 is challenged on the ground that the petitioner did not have a reasonable opportunity to explain the discrepancies.
2. Mr. I. Dinesh, learned Additional Government Pleader (Tax), accepts notice on behalf of the respondent.
3. Adverting to the petitioner’s reply to the show cause notice, learned counsel for the petitioner submits that the petitioner stated that M/s. S K N Aqua filed the GSTR 3B returns belatedly and that Input Tax Credit (ITC) was not claimed in relation to said supplier. He also submits that recoveries were made to the extent of Rs.3,89,996/- from the petitioner’s electronic credit ledger. Subject to giving credit thereto, learned counsel submits, on instructions, that the petitioner agrees to remit 50% of the tax demand of Rs.15,89,486/- under the impugned order. An endorsement has been made on the bundle to that effect.
4. Subject to the petitioner remitting additional amounts so as to remit 50% of the tax demand under the impugned order in the aggregate within thirty
WP No. 37819 of 2026
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 confirmed tax proposals on merits. After providing a reasonable opportunity to the petitioner, a fresh order shall be issued in relation to the confirmed tax proposals within five months from the date of remittance in the manner specified above. Subject to the fulfilment of this condition, any attachment relating to the impugned order, including measures against garnishees, shall be raised or not proceeded with, as the case may be.
5. The writ petition is disposed of on the above terms. Consequently, connected miscellaneous petitions are closed. There shall be no order as to costs. 23-09-2026 Index : Yes/No Neutral Citation : Yes/No KJ To The Deputy State Tax Officer - 2 Sriperumbudur Assessment Circle, office of the Assistant Commissioner (ST), No.4/109, Varadarajapuram, Chennai - Bangalore Highway, Room No.12, ground floor, Chennai - 600123.
WP No. 37819 of 2026
SENTHILKUMAR RAMAMOORTHY, J. KJ WP No. 37819 of 2026 23-09-2026