Archana Vs The Deputy State Tax Officer

Petition filed under Article 226 of the Constitution of India to issue a Writ of Certiorarified Mandamus to call for the records of the impugned order of the 1st respondent i.e., i) order in GST No.33AKCPC3671P1Z3, dated 07.05.2025, ii) order in Reference

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W.P.No.17912 of 2026

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No.ZD331125366126M, dated 20.11.2025 and iii) order in Reference No.ZD331125366126M, dated 20.11.2025 of the 1st respondent and quash the same and consequentially direct the 1st respondent to raise the attachment made in the Petitioner’s Bank account in Current Account No.936201002941, IFSC CNRB0000936, Canara Bank, Ambattur Branch, Chennai.

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For Petitioner : Mr.R.Rajeshkrishnan For Respondents : Mr.TNC Kaushik Additional Government Pleader

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O R D E R

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This writ petition has been filed challenging the orders of the first respondent i.e., i) order in GST No.33AKCPC3671P1Z3, dated 07.05.2025, ii) order in Reference No.ZD331125366126M, dated 20.11.2025 and iii) order in Reference No.ZD331125366126M, dated 20.11.2025 and for consequential direction to the first respondent to raise the attachment made in the petitioner’s Bank account in Current Account No.936201002941, IFSC CNRB0000936, Canara Bank, Ambattur Branch, Chennai.

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2.The learned counsel appearing for the petitioner submitted

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that the petitioner is engaged in the business of steel furniture and fabrication works and is registered under the provisions of the TNGST Act and that the impugned orders have been passed without giving an 2/6

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opportunity of hearing to the petitioner. The learned counsel further submitted that the petitioner is ready and willing to pay 25% of the disputed tax liability.

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3.Heard the learned counsel appearing for the petitioner as

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well as the learned learned Additional Government Pleader appearing

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for the respondents and carefully perused the materials available on record.

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4.In view of the fact that, though the notices were uploaded in the GST portal, the petitioner was not given an opportunity of hearing to submit their clarifications before the impugned orders were passed and considering the undertaking given by the learned counsel appearing for the petitioner that the petitioner is ready and willing to pay 25% of the disputed tax liability, this Court is inclined to dispose of this writ petition with the following directions:

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(i) The impugned orders dated 07.05.2025, 20.11.2025 and 20.11.2025 are set aside and the matter is remanded back to the respondents for fresh consideration subject to the condition that the petitioner deposits 25% of the disputed tax liability.

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(ii)On such deposit being made by the petitioner, the first respondent shall raise the attachment made in the petitioner’s Bank account in Current Account No.936201002941, IFSC CNRB0000936, Canara Bank, Ambattur Branch, Chennai and the respondents shall consider the matter afresh and pass appropriate orders as expeditiously as possible.

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(iii)If the petitioner fails to comply with the above stipulation,

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the respondents shall proceed against the petitioner to recover tax in accordance with law.

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