Madras High CourtWP/16609/2026disposed of

S 878 Kalvadangam Primary v. The Assistant Commissioner (State Taxes)

2026-06-01Honourable Mr Justice Senthilkumar Ramamoorthy4 pages

IN THE HIGH COURT OF JUDICATURE AT MADRAS

DATED: 01-06-2026

CORAM

THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY and W.M.P.Nos.17860 & 17862 of 2026 S 878 Kalvadangam Primary Agricultural Co-Operative Credit Society Limited Represented by its Secretary, Venkidusamy, 4/136, Koneripatty Thevoor Via, Mettangadu Post Sankari, Salem, Tamil Nadu- 637 104 ..Petitioner(s) Vs The Assistant Commissioner (State Taxes) (also known as the Deputy Commercial tax officer) Sankari Assessment circle, 1st Floor, Tiruchengode Road, RDO Complex, Sankari-637 301 ..Respondent(s) PRAYER: Writ Petition is filed under Article 226 of the Constitution of India, pleased to issue a Writ of Certiorari, calling for the records on the files of the learned Respondent herein in GSTIN/ 33AAFAS0056G1ZU/ 2018-19 in FORM GST DRC-07 in Order Reference No. ZD330324162502T dated 25.03.2024 and quash the same For Petitioner(s):

M/s.SIRI CHANDANA For Respondent(s):

Ms.Amirta Poonkodi Dinakaran, Government Counsel (Tax)

ORDER

An order dated 25.03.2024 is assailed in this writ petition on the ground that the petitioner was not provided a reasonable opportunity to explain the disparity between the GSTR-3B returns and the auto-populated GSTR-2A.

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

3. The period of limitation for filing an appeal has long expired. On instructions, learned counsel for the petitioner agrees to pay 50% of the disputed tax demand. An endorsement to that effect is made on the bundle.

4. Considering the aforesaid, subject to payment of 50% of disputed tax demand by the petitioner, as agreed to, within four weeks from the date of receipt of a copy of this order, the order impugned herein is set aside and the matter is remanded for re-consideration.

5. After providing a reasonable opportunity to the petitioner, a fresh order shall be passed, the above mentioned condition is complied with. Such fresh order shall be issued within three months from the date of compliance with the

above condition. No costs. Consequently, the connected writ miscellaneous petitions are closed.

01-06-2026 (2/3) Index: Yes/No Speaking/Non-speaking order RNA To The Assistant Commissioner (State Taxes) (also known as the Deputy Commercial tax officer) Sankari Assessment circle, 1st Floor, Tiruchengode Road, RDO Complex, Sankari-637 301

SENTHILKUMAR RAMAMOORTHY, J.

RNA and W.M.P.Nos.17860 & 17862 of 2026 01-06-2026 (2/3)