Super Max Cnc Centre Private Limited v. The State Tax Officer, (Fac)

ORDER Mrs.Amirtha Poonkodi Dinakaran, learned Government Advocate, takes notice for the Respondent.

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

¶3In this Writ Petition, the Petitioner has challenged the impugned Order dated 24.12.2025, which was preceded by a Show Cause Notice in GST DRC-01 dated 25.07.2025 wherein the Petitioner was called upon to appear for personal hearing. However, the Petitioner had not taken advantage of the same and thus, suffered the impugned Order dated 24.12.2025.

¶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 02.04.2026.

¶5At this stage, the learned counsel for the Petitioner submits that the Petitioner is willing to pre-deposit 10% of the disputed tax as a condition for denovo adjudication. Page3 of 6

¶6The learned counsel for the Petitioner has also made an following endorsement to that effect in the Court bundle which has been extracted hereunder:- "Consent to 10% Tax deposit."

¶7Recording the above submission, the case is remitted back to the Respondent to pass a fresh order on merits subject to the Petitioner depositing 10% of the disputed tax in cash or 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.

¶8Needless to state, any amount recovered from the Petitioner / paid by the Petitioner, towards the tax liability confirmed vide impugned order, shall be adjusted towards the aforesaid pre-deposit of 10% as ordered above. This will be however subject to verification by the first Respondent.

¶9Within such time, the Petitioner shall also file a reply to the Show Cause Notice in GST DRC-01 dated 25.07.2025 together with requisite documents to substantiate the case by treating the impugned Order dated

24.12.2025 as an addendum to the Show Cause Notice dated 25.07.2025. Page4 of 6

¶10In case the Petitioner complies with the above stipulations, the 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 if any, shall also stand automatically vacated.

¶11It is made clear that bank attachment shall be lifted subject to the Petitioner depositing 10% 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.

¶12In case the Petitioner fails to comply with any of the stipulations, the 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.

¶13Needless to state, before passing any such order, the Respondent shall give due notice to the Petitioner. Page5 of 6

¶14This Writ Petition stands disposed of with the above observations. No costs. Connected Writ Miscellaneous Petitions are closed.

22.04.2026 Index: Yes/No Speaking/Non-speaking order kmm To The State Tax Officer, (FAC) Pattaravakkam Assessment Circle, No.3/109, Integrated Commercial Tax Building, Room No.6, Bangalore Theni Highway Road, Varatharajapuram, Poonnamallee, Thiruvallur, Tamil Nadu - 600 123. Page6 of 6

C.SARAVANAN, J. kmm W.P.No.15311 of 2026

22.04.2026

Page1 of 6 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 22.04.2026 CORAM THE HON'BLE MR JUSTICE C. SARAVANAN W.P.No.15311 of 2026 and W.M.P.Nos.16519 & 16521 of 2026 Super Max CNC Centre Private Limited Represented by its Director T.N.Kannan 31A, 31B, SIDCO Industrial Estate, Ambattur, Chennai, Thiruvallur, Tamil Nadu - 600 098. ..Petitioner Vs The State Tax Officer, (FAC) Pattaravakkam Assessment Circle, No.3/109, Integrated Commercial Tax Building, Room No.6, Bangalore Theni Highway Road, Varatharajapuram, Poonnamallee, Thiruvallur, Tamil Nadu - 600 123. ..Respondent PRAYER: Writ Petition filed under Article 226 of the Constitution of India, for issuance of a Writ of Certiorari, calling for the records on the files of the Respondent herein, in the Impugned Order in GSTIN/ 33AAWCS4979H1ZJ/2021-22 dated 24.12.2025 along with FORM GST DRC - 07 Order Reference No.ZD3312253971198 dated 26.12.2025 and quash the same. For Petitioner : Mr.K.A.Parthasarathi For Respondent : Mrs.Amirtha Poonkodi Dinakaran Government Advocate. Page2 of 6