Sri Pachaiamman Pori Mundy, Vs the State Tax Officer… — Writ and Judicial Review | Madras HC (2026)

Sri Pachaiamman Pori Mundy, Vs the State Tax Officer… — Writ and Judicial Review | Madras HC (2026)

What the court decided

AI extract

Outcome

Impugned orders dated 21.01.2026 set aside and matters remanded for re-consideration, subject to the petitioner remitting 10% of the disputed tax demand in respect of each order within thirty days; fresh orders to be issued within three months of remittance after providing reasonable opportunity; connected miscellaneous petitions closed; no order as to costs.

Issue for consideration

Whether the orders dated 21.01.2026 passed by the respondent in proceedings GSTIN - 33ACKFS2695B1Z4/2019-20 and GSTIN - 33ACKFS2695B1Z4/2020-21 were vitiated by breach of principles of natural justice and liable to be quashed.

Court's answer

On instructions, learned counsel for the petitioner agreed to pay 10% of the disputed tax demand in respect of each order, and the Court directed that subject to the petitioner remitting 10% of the disputed tax demand in respect of each order within thirty days from receipt of a copy of the order, the impugned orders are set aside and the matters remanded for re-consideration.

Ratio / Principle

After providing a reasonable opportunity to the petitioner, fresh orders shall be issued within three months from the date of remittance of 10% of the disputed tax demand.

Key takeaways

The impugned orders are set aside and the matters are remanded for re-consideration.ratio¶25
The writ petitions are disposed of on the above terms; connected miscellaneous petitions are closed; there shall be no order as to costs.ratio¶29-30

Detailed headnote1 paragraphs

Madras High Court (Senthilkumar Ramamoorthy, J.), disposing of two writ petitions under Article 226 of the Constitution of India challenging two orders each dated 21.01.2026 passed by the State Tax Officer (Review) in proceedings GSTIN - 33ACKFS2695B1Z4/2019-20 and GSTIN - 33ACKFS2695B1Z4/2020-21, assailed on the ground of alleged breach of principles of natural justice. Learned counsel for the petitioner agreed, on instructions, to pay 10% of the disputed tax demand for each order. Subject to remittance of 10% of the disputed tax demand in respect of each order within thirty days of receipt of the order, the impugned orders were set aside and the matters remanded for re-consideration; fresh orders are to be issued within three months from the date of remittance after providing reasonable opportunity to the petitioner. Connected miscellaneous petitions were closed; no order as to costs.

WP Nos. 23456 & 23461 of 2026

IN THE HIGH COURT OF JUDICATURE AT MADRAS

DATED: 01-07-2026

CORAM

THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP Nos. 23456 & 23461 of 2026 and WMP.Nos.25438, 25442, 25447 & 25449 of 2026

In both WPs.

Sri Pachaiamman Pori Mundy, Rep By Its Proprietor, S.Vilwanathan No.11/1b, By Pass Road, Perumalpet, Vaniyampadi - 635 752.

..Petitioner

Vs

The State Tax Officer (Review) Office of the Joint Commissioner (ST)(INTL), No.4, Bharathiar Salai, Fort Round, Vellore -632 001.

..Respondent

Prayer in W.P.No.23456 of 2026 : Writ Petition is filed under Article 226 of the Constitution of India praying for issuance of Writ of Certiorari to call for the records of the respondent in his proceeding in GSTIN - 33ACKFS2695B1Z4/2019-20 and quash the proceeding dated 21.01.2026 passed therein.

Prayer in W.P.No.23461 of 2026 : Writ Petition is filed under Article 226 of the Constitution of India praying for issuance of Writ of Certiorari to call for the records of the respondent in his proceeding in GSTIN - 33ACKFS2695B1Z4/2020-21 and quash the proceeding dated 21.01.2026 passed therein.

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WP Nos. 23456 & 23461 of 2026

In both WPs.

For Petitioner: Mr. Raveendran B For Respondent: Ms. Amirta Poonkodi Dinakaran Government Counsel (Tax)

COMMON ORDER

Orders, each dated 21.01.2026, are assailed in these two writ petitions on the ground of alleged breach of principles of natural justice.

Ms. Amirta Poonkodi Dinakaran, learned Government Counsel (Tax), accepts notice on behalf of the respondent.

On instructions, learned counsel for the petitioner agrees to pay 10% of

the disputed tax demand in respect of each order. An endorsement to that effect is made on the bundle.

Subject to the condition that the petitioner remits 10% of the disputed

tax demand in respect of each order, as agreed to, within thirty days from the date of receipt of a copy of this order, the impugned orders are set aside and the matters are remanded for re-consideration. After providing a reasonable opportunity to the petitioner, fresh orders shall be issued within three months from the date of remittance of 10% of the disputed tax demand.

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WP Nos. 23456 & 23461 of 2026

The writ petitions are disposed of on the above terms. Consequently,

connected miscellaneous petitions are closed. There shall be no order as to costs.

01-07-2026

Index : Yes/No (1/2) Neutral Citation : Yes/No KJ To

The State Tax Officer (Review) Office of the Joint Commissioner (ST)(INTL), No.4, Bharathiar Salai, Fort Round, Vellore -632 001.

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WP Nos. 23456 & 23461 of 2026

SENTHILKUMAR RAMAMOORTHY, J.

KJ

WP Nos. 23456 & 23461 of 2026 and WMP.Nos.25438, 25442, 25447 & 25449 of 2026

01-07-2026 (1/2)

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