Mundlapatti Inder Raju Sai Vineeth Vs Deputy State Tax Officer

the same and direct the first respondent to Defreeze or lift the attachment of bank account i.e., A/c.No.69460500000020 of the Recovery notice dated 2.1.2026 issued to the second respondent.

¶20

For Petitioner : Mr.N.Saravanan

¶21

For Respondent : Mr.TNC.Kaushik Additional Government Pleader for R.1

¶22

¶23

ORDER

¶24

Mr.TNC Kaushik, learned Additional Government Pleader, takes notice for the first Respondent.

¶25

This Writ Petition is being disposed of at the stage of admission itself

¶26

with the consent of the learned counsel for the Petitioner and the learned

¶27

Additional Government Pleader for the first Respondent.

¶28

In this Writ Petition, the Petitioner has challenged the impugned Order

¶29

dated 13.03.2024, which was preceded by a Show Cause Notice in GST DRC-01 dated 07.09.2023, wherein the Petitioner was called upon to file a reply and to appear for a personal hearing. However, the Petitioner did not take

¶30

2/6

¶31

https://www.mhc.tn.gov.in/judis

¶32

W.P.No.10688 of 2026 advantage of the same and has thus suffered the impugned Order dated 13.03.2024.

¶33

It is noticed that the limitation for filing an appeal under Section 107 of

¶34

the respective GST enactments, 2017 against the impugned Order has already expired long before. However, the present Writ Petition has been filed only on 12.03.2026.

¶35

At this stage, the learned counsel for the Petitioner submits that the Petitioner is willing to pre-deposit 50% of the disputed tax as a condition for denovo adjudication and he has also made an endorsement to that effect in the Court bundle, which has been extracted hereunder:-

¶36

“Ready and willing to deposit 50% of the amount in the impugned order”.

¶37

Recording the above consent given by the Petitioner, the case is

¶38

remitted back to the first Respondent to pass a fresh order on merits subject to

¶39

the Petitioner depositing 50% of the disputed tax in cash or from the Petitioner's Electronic Cash Register within a period of thirty (30) days from the date of receipt of a copy of this order.

¶40

3/6

¶41

https://www.mhc.tn.gov.in/judis

¶42

W.P.No.10688 of 2026

¶43

Within such time, the Petitioner shall also file a reply to the Show

¶44

Cause Notice in GST DRC-01 dated 27.09.2023 together with requisite documents to substantiate the case by treating the impugned Order dated 13.03.2024 as an addendum to the Show Cause Notice dated 27.09.2023.

¶45

In case, the Petitioner complies with the above stipulations, the first Respondent shall proceed to pass a final order on merits and in accordance with law as expeditiously as possible, preferably, within a period of three (3) months of such reply/pre-deposit. Subject to the Petitioner complying with the above stipulations, the attachment of the bank account of the Petitioner if any, shall also stand automatically vacated.

¶46

It is made clear that bank attachment shall be lifted subject to the Petitioner depositing 50% of the disputed tax as ordered above and the Petitioner not being in arrears of any other amount for any other tax period barring the amount demanded under the impugned Order.

¶47

In case the Petitioner fails to comply with any of the stipulations, the first Respondent is at liberty to proceed against the Petitioner to recover the tax

¶48

in accordance with law as if this Writ Petition was dismissed in limine today. 4/6

¶49

https://www.mhc.tn.gov.in/judis

¶50

W.P.No.10688 of 2026

¶51