Madras High Court

WP/36736/2026 of Ranganathan Textiles Vs The Commercial tax officer on 22 September 2026

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WP No. 36736 of 2026

IN THE HIGH COURT OF JUDICATURE AT MADRAS

DATED: 22.09.2026

CORAM

THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY

WP No. 36736 of 2026

CNR:{HCMA012020802026}

M/s.Ranganathan Textiles

Represented by its Proprietor,

Mr. Ahyeegoundanpalayam Chikkannachettiyar Thirumoorthi, 3/386, Perumal Koil street, Vembadithalam, Salem, Tamil Nadu 637 504

..Petitioner

Vs

The Commercial Tax Officer

Salem Rural Assessment Circle,

Integrated Commercial Taxes Building,

1st Floor, BSNL -opp Mohanur Road,

Salem -637 001

..Respondent

Writ Petition filed under Article 226 of the Constitution of India praying to issue a writ of certiorarified mandamus calling for the records of the Respondent in respect of the impugned order in Form GST DRC-07

bearing Reference No. ZD331225058392K dated 04.12.2025 for the Financial Year 2021-22 and quash the same, and forthwith direct Respondent to redo the assessment proceedings in accordance with law after affording a reasonable opportunity of personal hearing to the petitioner and pass order in Appeal within time frame as fixed by this Court.

For Petitioner:

Mr. R.Suryanarayanan

For Respondent:

Ms.Amirta Poonkodi Dinakaran,

Additional Government Pleader (Tax)

WP No. 36736 of 2026

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ORDER

An order dated 04.12.2025 is assailed on the ground that the petitioner did not have a reasonable opportunity to contest the tax demand on merits.

2. Ms.Amirta Poonkodi Dinakaran, learned Additional Government Pleader (Tax), accepts notice for the respondent.

3. Learned counsel for the petitioner submits that more than 25% of the tax demand under the impugned order was recovered. He relies on the electronic liability ledger in this regard. This aspect is required to be verified and confirmed.

4. Subject to verifying and confirming the recovery of more than 25% of the tax demand under the impugned order, the impugned order is set aside and the matter is remanded for reconsideration so as to provide an opportunity to the petitioner to contest the tax proposal on merits. After providing a reasonable opportunity to the petitioner, a fresh order shall be issued within five months from the date of confirming the above mentioned recovery. In view of the impugned order being set aside, the bank attachment, if any, relating to the impugned order shall stand raised.

WP No. 36736 of 2026

5. The writ petition is disposed of on the above terms. There shall be no order as to costs. 22.09.2026 Index: Yes/No Neutral Citation: Yes/No mmi To The Commercial Tax Officer Salem Rural Assessment Circle, Integrated Commercial Taxes Building, 1st Floor, BSNL -opp Mohanur Road, Salem -637 001.

WP No. 36736 of 2026

SENTHILKUMAR RAMAMOORTHY, J. mmi WP No. 36736 of 2026 22.09.2026

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