M/S.Seemati Ready Made Cut Piece Centre v. The State Tax Officer,

ORDER Mrs.P.Selvi, learned Government Advocate takes notice for the Respondents.

¶2This Writ Petition is being disposed of at the time of admission with the consent of the learned counsel for the Petitioner and the learned Government Advocate for the Respondents.

¶3In this Writ Petition, the Petitioner has challenged the impugned Order in FORM GST DRC-07 bearing Ref.No.ZD330825198799E dated

19.08.2025 passed by the 1st Respondent along with consequential impugned Recovery Notice in FORM GST DRC-13 bearing GSTIN: 33AATFS5776N1Z6/Apr-2018 to Mar-2019 dated 21.11.2025 of the 2nd Respondent, which was preceded by a Show Cause Notice in GST DRC-01 dated 29.11.2023 wherein the Petitioner was also called upon to appear for personal hearing. However, the Petitioner had not taken advantage of the same and thus, suffered the impugned Order dated 19.08.2025.

¶4It is noticed that the limitation for filing an appeal under Section 107 of the respective GST enactments, 2017 against the impugned Order has already expired. The present Writ Petition has been filed only on

27.03.2026.

¶5At this stage, the learned counsel for the Petitioner submits that the Petitioner is willing to pre-deposit 25% of the disputed tax as a condition for de novo adjudication.

¶6The learned counsel for the Petitioner has also made an endorsement to that effect in the Court Bundle, which is extracted hereunder:-

"Petitioner undertakes to deposit 25% of the tax demanded in the Impugned Order."

¶7Recording the same, the case is remitted back to the 1st Respondent to pass a fresh order subject to the Petitioner depositing 25% of the disputed tax in cash from the Petitioner's Electronic Cash Register within a period of thirty (30) days from the date of receipt of a copy of this order.

¶8Within such time, the Petitioner shall also file a reply to the Show Cause Notice in GST DRC-01 dated 29.11.2023 together with requisite documents to substantiate the case by treating the impugned Order dated

19.08.2025 as an addendum to the Show Cause Notice dated 29.11.2023.

¶9In case the Petitioner complies with the above stipulations, the 1st Respondent shall proceed to pass a final order on merits and in accordance with law as expeditiously as possible, preferably, within a period of three (3) months of such reply / pre-deposit. Subject to the Petitioner complying with the above stipulations, the attachment of the bank account of the Petitioner shall also stand automatically vacated.

¶10It is made clear that bank attachment shall be lifted subject to the deposit of 25% of the disputed tax as ordered above and the Petitioner not being in arrears of any other amount for any other tax period barring the amount demanded under the impugned Order.

¶11In case the Petitioner fails to comply with any of the stipulations, the 1st Respondent is at liberty to proceed against the Petitioner to recover the tax in accordance with law as if this Writ Petition was dismissed in limine today.

¶12Needless to state, before passing any such order, the 1st Respondent shall give due notice to the Petitioner.

¶13This Writ Petition stands disposed of with the above observations. No costs. Connected Writ Miscellaneous Petitions are closed.

02.04.2026 arb To:

1.The State Tax Officer, Thirukazhukundram Assessment Circle, No.42, Wahab Nagar, Thirukazhukundram – 603 109.

2.Deputy Commissioner (ST), Chengalpattu Zone, No.26, Abhirami Complex, Kanchipuram High Road, Thimmavaram, Chengalpattu – 603 101.

C.SARAVANAN, J. arb and W.M.P.Nos.13820 and 13821 of 2026

02.04.2026

IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED : 02.04.2026 CORAM : THE HONOURABLE MR.JUSTICE C.SARAVANAN and W.M.P.Nos.13820 and 13821 of 2026 M/s.Seemati Ready Made Cut Piece Centre, Represented by its Partner A.Mary Lathies ... Petitioner Vs. 1.The State Tax Officer, Thirukazhukundram Assessment Circle, No.42, Wahab Nagar, Thirukazhukundram – 603 109. 2.Deputy Commissioner (ST), Chengalpattu Zone, No.26, Abhirami Complex, Kanchipuram High Road, Thimmavaram, Chengalpattu – 603 101. ... Respondents Prayer: Writ Petition filed under Article 226 of the Constitution of India, for issuance of a Writ of Certiorari, to call for the records pertaining to the impugned order vide DRC-07 Reference No.ZD330825198799E dated 19.08.2025 passed by the 1st Respondent for the assessment year 2018-2019 and the consequential impugned recovery notice vide FORM DRC-13 dated 21.11.2025 passed by the 2nd Respondent and quash the same. For Petitioner : Mr.G.Derrick Sam For Respondents : Mrs.P.Selvi Government Advocate