BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT DATED : 20.01.2026 CORAM THE HONOURABLE MR.JUSTICE KRISHNAN RAMASAMY & W.M.P.(MD)Nos.848, 849, 851 to 854, 857 & 858 of 2026 M/s. Mathusamy Thangamuthu Nachiyar Having its Office at No.1F1-D5, Aringar Anna Street Kovilpatti, Thoothukudi District Tamilnadu - 628 501 Represented by its Proprietor M. Thangamuthu Nachiyar ... Petitioner in all petitions Vs.

1. The Commissioner Of Commercial Taxes Ezhilagam, Chepauk, Chennai - 600 005.

2. The State Tax Officer Office of the Commercial Taxes Department Kovilpatti - 1 Circle, Thoothukudi District Tamil Nadu.

3. The Branch Manager The Federal Bank Kovilpatti Branch.

... Respondents in all petitions Common Prayer:

Writ Petition filed under Article 226 of the Constitution of India praying to issue a Writ of Certiorarified Mandamus, calling for the records and to quash the ex-parte final order in cancelled GSTIN - 33ADXPT2445G1Z5 (2022-23) dated 04.06.2025 and consequently direct the respondents to treat the GST-TDS for FY 2022-23 as validly credited under new GSTIN - 33DXPT2445G2Z4 and to drop all proceedings initiated under the cancelled GSTIN and to forthwith defreeze the petitioners bank account.

calling for the records and to quash the ex-parte final order in cancelled GSTIN - 33ADXPT2445G1Z5 (2023-24) dated 16.07.2025 and consequently direct the respondents to treat the GST-TDS for FY 2023-24 as validly credited under new GSTIN - 33DXPT2445G2Z4 and to drop all proceedings initiated under the cancelled GSTIN and to forthwith defreeze the petitioners bank account calling for the records and to quash the ex-parte final order in cancelled GSTIN - 33ADXPT2445G1Z5 (2020-21) dated 04.06.2025 passed in respect of the cancelled GSTIN 33ADXPT2445G1Z5 and consequently direct the respondents to treat the GST-TDS for FY 2020-21 as validly credited under new GSTIN - 33DXPT2445G2Z4 and to drop all proceedings initiated under the cancelled GSTIN and to forthwith defreeze the petitioners bank account calling for the records and to quash the ex-parte final order in cancelled GSTIN. 33ADXPT2445G1Z5 (2024-25) dated 04.06.2025 and consequently direct the respondents to treat the GST-TDS for FY 2024-25 as validly credited under new GSTIN 33DXPT2445G2Z4 and to drop all proceedings initiated under the cancelled GSTIN and to forthwith defreeze the petitioner's bank account For Petitioner in all petitions : Ms.G.Dhanalakshmi For Respondent in all petitions : Mr.R.Suresh Kumar, AGP

COMMON ORDER

These writ petitions have been filed challenging the impugned orders dated 04.06.2025 & 16.07.2025 passed by the respondent.

2. Mr.R.Suresh Kumar, learned Additional Government Pleader, takes notice on behalf of the respondents.

3. By consent of the parties, the main writ petitions are taken up for disposal at the admission stage itself.

4. The learned counsel for the petitioner would submit that in these cases, the petitioner's old GST number was suo moto cancelled by the respondent on 31.12.2019. Subsequently, they obtained the new GST No.33ADXPT2445G2Z4 on 27.07.2021. Under these circumstances, all notices/communications, pertaining to the old GST number, were uploaded by the respondent in the GST common portal. Since the petitioner was not aware of the said notices, they failed to file their reply within the time. At this juncture, the impugned orders came to be passed by the respondent without providing any opportunity of personal hearing to the petitioner. Therefore, these petitions have been filed.

5. Further, he would submit that now the petitioner is willing to pay 25% of the disputed tax amount to the respondent in each case. Hence, he requests this Court to grant an opportunity to the petitioner to present their case before the respondent by setting aside the impugned orders. He would also request this Court to lift the attachment order for making payment of 25% of the disputed tax amount as stated above.

6. On the other hand, the learned Additional Government Pleader appe