Tvl. Kongunadu Infrastructure Llp v. Joint Commissioner (St),

Page1 of 4 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 06-07-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP Nos. 22604 & 22606 of 2026 & WMP Nos.24510, 24512, 24518 & 24519 of 2026 In both WPs Tvl. KONGUNADU INFRASTRUCTURE LLP Represented By Its Partner K.Thangavelu,No. 9/119A, Vazhai Thottam, Kolli Hills Main Road, Kalanappanaickenpatti, Namakkal - 637404. ..Petitioner(s) Vs

¶1Joint Commissioner (ST), Intelligence, Salem, Commercial Taxes Buildings, Hasthampatti, Salem – 636007.

¶2State Tax Officer (FAC) Intelligence, Salem/Commercial Tax Officer, Salem, Office of the Joint Commissioner (ST), Intelligence, Salem, Combined Commercial Tax Building, Hasthampatti, Salem - 636007. ..Respondent(s) Prayer in W.P.No.22604 of 2026 : Writ Petition is filed under Article 226 of the Constitution of India praying for issuance of Writ of Certiorarified Mandamus calling for the records on the file of the Respondent and impugned order in Reference No. ZD3304242280501 passed by the 2ND Respondent under section 74 and 50 of the TNGST Act, 2017 dated 28.04.2024 for the Financial Year 2020-21 and quash the same as illegal and not in accordance with law and consequently direct the 2nd Respondent to conduct fresh assessment proceedings after providing a reasonable opportunity of hearing to the Petitioner in accordance with law. Page2 of 4 Prayer in W.P.No.22606 of 2026 : Writ Petition is filed under Article 226 of the Constitution of India praying for issuance of Writ of Certiorarified Mandamus calling for the records on the file of the Respondent and impugned order in Reference No. ZD330424228029M passed by the 2nd Respondent under Section 74 and 50 of the TNGST Act, 2017 dated 28.04.2024 for the Financial Year 2020-21 and quash the same as illegal and not in accordance with law and consequently direct the 2nd Respondent to conduct fresh assessment proceedings after providing a reasonable opportunity of hearing to the Petitioner in accordance with law. In both WPs For Petitioner(s): Ms.Vandana Vyas For Respondent(s): Ms.Amirta Poonkodi Dinakaran Government Counsel (Tax) COMMON ORDER Assessment orders dated 28.04.2024 are assailed in both these writ petitions on the ground of alleged breach of principles of natural justice.

¶2Ms. Amirta Poonkodi Dinakaran, learned Government Counsel (Tax), accepts notice on behalf of the respondents.

¶3The period of limitation for filing appeals has expired. On instructions, learned counsel for the petitioner agrees to pay 50% of the disputed tax demand in respect of each assessment order. An endorsement to that effect is made on the bundle. Page3 of 4

¶4Subject to the condition that the petitioner remits 50% of the disputed tax demand in respect of each assessment order, as agreed to, within a period of four months from the date of receipt of a copy of this order, the impugned assessment orders are set aside and the matter is remanded for re-consideration. After providing a reasonable opportunity to the petitioner, fresh assessment orders shall be issued within three months from the date of remittance of 50% of the disputed tax demand.

¶5The writ petitions are disposed of on the above terms. Consequently, connected miscellaneous petitions are closed. There shall be no order as to costs. 06-07-2026 Index: Yes/No Speaking/Non-speaking order KAL Page4 of 4

SENTHILKUMAR RAMAMOORTHY, J. KAL To

¶1The Joint Commissioner (ST), Intelligence, Salem, Commercial Taxes Buildings, Hasthampatti, Salem – 636007.

¶2The State Tax Officer (FAC) Intelligence, Salem/Commercial Tax Officer, Salem, Office of the Joint Commissioner (ST), Intelligence, Salem, Combined Commercial Tax Building, Hasthampatti, Salem - 636007. WP Nos. 22604 & 22606 of 2026 & WMP Nos.24510, 24512, 24518 & 24519 of 2026 06-07-2026