The authority must supply the assessee with copies of seized electronic data if the assessment is based on such materials to ensure compliance with the principles of natural justice and provide a fair opportunity for defense.

BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT DATED: 29.04.2026 CORAM THE HON'BLE MR.JUSTICE D.BHARATHA CHAKRAVARTHY and W.M.P(MD)No.10080 of 2026 Tvl.Shree Narsingh Sweets Limited, Rep. by its Managing Director Jeevraj Rajpurohit No.22, Pookara Street, Madurai Main, Madurai-625 001. .. Petitioner Vs.

The State Tax Officer/Commercial Tax Officer, Inspector Cell-IV, Madurai. .. Respondent Prayer: Writ Petition is filed under Article 226 of the Constitution of India, praying this Court to issue a Writ of Certiorarified Mandamus, to call for the impugned assessment order on the file of respondent vide GSTIN 33AABCN6923D1ZT/2023-24 and in summary order Reference No. ZD3302206130911S and ZD330226130625P dated 16.02.2026 and quash the same as illegal and as devoid of merits and direct the respondent to redo the assessment for the year 2023-24 afresh after following the due process of law.

For Petitioner : Mr.Raja Karthikeyan For Respondent : Mr.R.Suresh Kumar Additional Government Pleader

ORDER

This writ petition is filed challenging the impugned order dated

16.02.2026.

2. The said order is an order of assessment passed under Section 74 of the Tamil Nadu Goods and Services Act, 2017.

3. Upon hearing the learned counsel for the petitioner and perusing the material records, it is seen that when the inspection was carried out in the petitioner's premises, it was found that certain turnover has been suppressed and based on the materials seized during the inspection, a show cause notice was issued.

4. In reply to the show cause notice, the petitioner sought copies of the documents seized from the computer of the petitioner. According to the learned counsel for the petitioner, when the petitioner is carrying on business under three different entities, namely, a public limited company, a proprietorship concern and yet another proprietorship concern, having three distinct accounts, the authorities have confused with the turnovers of the three concerns. If the entire date taken from the computer is made available, the petitioner would be in a position to submit an effective reply to the show cause notice on merits.

5. Per Contra, the learned Additional Government Pleader would submit that normally, at the time of inspection, whatever the documents are seized, a copy will also be issued to the assessee at the time itself. The assessee has not made any demand that no copy was given to him. This apart, the petitioner has an alternative remedy by way of appeal against the said order.

6. I have considered the rival submissions made on either side.

7. In this case, though an appeal remedy is available, the writ petition has been filed only on the ground of violation of principles of natural justice. According to the learned counsel for the petitioner, the opportunity given should be a fair opportunity. When it is alleged that the hard disk from the petitioner premises during the inspection have been seized, from the records it is seen that from the earliest point of time, the petitioner is seeking a copy of the said data.

8. Considering the nature of the discrepancies alleged and the contention of the petitioner that turnovers of different entities are being confused entry, I am of the view that the petitioner deserves an opportunity to submit a detailed explanation with reference to each of the discrepancy on merits. The same is possible, if only the respondents supply the entire data that is taken away from the petitioner, which is said to be contained in the hard disk.

9. In view thereof, this writ petition is allowed on the following terms:-

(i) The impugned order dated 16.02.2026 shall stand set aside and the matter is remanded back to the file of the respondents.

(ii) Within two weeks from the date of r