Madras High Court
WP/22047/2025 of Tvl Zonta Infratech Private Limited Vs State Tax Officer (Intelligence) on 14 October 2026
WP No. 22047 of 2025
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IN THE HIGH COURT OF JUDICATURE AT MADRAS
DATED: 14-10-2026
CORAM
THE HON'BLE MR JUSTICE KRISHNAN RAMASAMY
WP No. 22047 of 2025
CNR:{HCMA011290312025}
AND
WP NO. 22057 OF 2025,WP NO. 22052 OF 2025,WMP NO. 24783 OF
2025,WMP NO. 24785 OF 2025,WMP NO. 24789 OF 2025,WMP NO.
24790 OF 2025,WMP NO. 24781 OF 2025,WMP NO. 24782 OF 2025
Tvl. Zonta Infratech Private Limited,
Represented by its Director
Mr.Rajkumar Chellapan Pillai
Having its registered office at 1 Floor, Above TAFE, Raheja Chambers, No.12, Museum Road, Mahatma Gandhi Road, Bangalore North, Karnataka – 560 001
Branch office at- No.44/14. Ground Floor, Anna Nagar, Kitchipalayam, Salem-636015, Tamil Nadu.
..Petitioner(s)
in all W.Ps
Vs
State Tax Officer (Intelligence)
Inspection Cell-2,
Office of the Joint Commissioner (ST), Intelligence Commercial Taxes Building, Hasthampatti, Salem-636 007.
..Respondent(s)
in all W.Ps
Certiorarified Mandamus, calling for the records on the file of respondent in passing the impugned assessment order vide GSTIN Reference No.33AADCI3846A1Z2/2021-22 dated 08.11.2024 for the Financial Year
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WP No. 22047 of 2025
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2021-22 to quash the same as arbitrary, illegal and devoid of merit and further direct the Respondent to consider the submissions of the Petitioner on merits after granting an opportunity.
Certiorarified Mandamus, calling for the records on the file of Respondent in passing the impugned assessment order vide GSTIN Reference No.
33AADCI3846A1Z2/2022-23 dated 08.11.2024 for the Financial Year 2022-23
to quash the same as arbitrary, illegal and devoid of merit and further direct the Respondent to consider the submissions of the Petitioner on merits after granting an opportunity of hearing.
Certiorarified Mandamus, calling for the records on the file of Respondent in passing the impugned assessment order vide GSTIN Reference No.
33AADC13846AIZ2/2020-21 dated 08.11.2024 for the Financial Year 2020-21
to quash the same as arbitrary, illegal and devoid of merit and further direct the Respondent to consider the submissions of the Petitioner on merits after granting an opportunity of hearing.
For Petitioner(s)
in all W.Ps:
M/s.Shruthikka.S
For Respondent(s)
in all W.Ps:
Mr.B.Sivaraman
Government Advocate (T)
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WP No. 22047 of 2025
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Common Order
These writ petitions have been filed challenging the assessment orders dated 08.11.2024 for the Financial Years 2020-21; 2021-22 and 2022-23.
2. Learned counsel for the petitioner would submit that, the show cause notices dated 04.07.2024 were issued in Form DRC-01 for the Financial Years 2020-21; 2021-22 and 2022-23. In response, the petitioner submitted detailed replies on 29.10.2024. However, without considering the replies filed by the petitioner and without affording an opportunity of personal hearing, the respondent confirmed the proposal made in the show cause notices by passing the impugned assessment orders dated 08.11.2024 in respect of the Financial Years 2020-21; 2021-22 and 2022-23.
3. He would further submit that despite the petitioner having filed replies to the show cause notices dated 04.07.2024, the respondent erroneously recorded that no replies had been filed and proceeded to confirm the demands. Hence, he prayed to set aside the impugned orders and to direct the respondent to afford the petitioner an opportunity of personal hearing to substantiate their case.
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WP No. 22047 of 2025 __________
4. Learned Government Advocate appearing for the respondent would fairly submit that no personal hearing opportunity was provided to the petitioner after the filing of replies and therefore, appropriate orders may be passed.
5. Heard the learned counsel for the petitioner as well as the learned Government Advocate appearing for the respondent and perused the materials available on record.
6. Considering the submissions made by the learned counsel for the petitioner as well as the learned Government Advocate appearing for the respondent, it is evident that the respondent proceeded to pass the impugned assessment orders without considering the replies filed by the petitioner and without affording an opportunity of personal hearing, which is totally against the provision under Section 75(4) of the Central Goods and Services Tax Act, 2017.
7. Thus, in such circumstances, this Court is of the view that the assessment orders were passed without affording an opportunity of personal hearing to the petitioner to establish their case, thereby violating the principles of natural justice and that it is just and necessary to afford the petitioner an opportunity of personal hearing to establish their case on merits and in accordance with law.
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8. For the foregoing reasons, this Court is inclined to set aside the impugned orders dated 08.11.2024 passed by the respondent. Accordingly, this Court pass the following orders:-
(i) The orders impugned herein are set aside and the matters are remanded back to the respondent for fresh consideration.
(ii) The respondent is directed to consider the replies dated 29.10.2024 filed by the petitioner 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.
9. With the above directions, these writ petitions are disposed of. There is no order as to costs. The connected miscellaneous petitions in W.M.P.Nos.24781, 24783 & 24789 of 2025 filed seeking to dispense with the production of original assessment order are ordered as prayed for and W.M.P.Nos.24782, 24785 & 24790 of 2025 filed seeking interim stay are hereby closed. 14-10-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No rst
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WP No. 22047 of 2025 __________
To State Tax Officer (Intelligence) Inspection Cell-2, Office of the Joint Commissioner (ST), Intelligence Commercial Taxes Building, Hasthampatti, Salem-636 007.
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WP No. 22047 of 2025 __________
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KRISHNAN RAMASAMY J. rst WP No. 22047 of 2025 AND WP NO. 22057 OF 2025,WP NO. 22052 OF 2025,WMP NO. 24783 OF 2025,WMP NO. 24785 OF 2025,WMP NO. 24789 OF 2025,WMP NO. 24790 OF 2025,WMP NO. 24781 OF 2025,WMP NO. 24782 OF 2025 14-10-2026
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