An impugned tax assessment order may be set aside and remanded for de novo consideration conditioned upon the payment of a specified portion of the disputed tax demand when there are allegations of a breach of natural justice.

Prayer: Writ petition is filed under Article 226 of the Constitution of India praying for issuance of writ of Certiorari calling for the records relating to the impugned proceedings passed by the respondent in the order vide GSTIN 33AACCM4647A1ZY/2021-22 dated 30.12.2025 along with the consequential summary order under section 73 of TNGST/CGST Act, 2017 issued vide FORM DRC-07 bearing Ref No. ZD331225437792D dated 30.12.2025 for the financial year 2021-2022, to quash the same and pass

ORDER

An order dated 30.12.2025 is assailed in this writ petition on the ground of alleged breach of principles of natural justice.

2. Mr. L.Gokulraj, learned Government Counsel (Tax), accepts notice on behalf of the respondent.

3. The period of limitation for filing an appeal has expired. On instructions, learned counsel for the petitioner agrees to pay 25% of the disputed tax demand. An endorsement to that effect is made on the bundle.

4. Subject to the condition that the petitioner remits 25% of the disputed tax demand, as agreed to, within thirty days from the date of receipt of a copy of this order, the impugned order is set aside and the matter is remanded for re-consideration. After providing a reasonable opportunity to the petitioner, a fresh order shall be issued within three months from the date of remittance of 25% of the disputed tax demand.

5. The writ petition is disposed of on the above terms. Consequently, connected miscellaneous petition is closed. There shall be no order as to costs.

11-06-2026

Index: Yes/No

Speaking/Non-speaking order

Neutral Citation: Yes/No

KAL