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Sms Conveyors v. The Deputy State Tax Officer 1

TAXATION – ASSESSMENT ORDER

Madras HC2 Jul 2026WP/23663/2026

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What is this about?

Madras High Court, Senthilkumar Ramamoorthy J., 02-07-2026; WP No. 23663 of 2026; SMS Conveyors v. Deputy State Tax Officer 1, Hosur (North 1) Assessment Circle; assessment/tax demand order FY 2021-22 (Ref. ZD3312253845385) passed without hearing; certiorari; remand conditioned on 25% deposit of disputed tax within 30 days; fresh order within 3 months; writ filed after limitation expired; connected WMPS 25619 & 25621 of 2026 closed; no costs.

What did the court decide?

Impugned order set aside and matter remanded for re-consideration, subject to remittance of 25% of the disputed tax demand within thirty days; fresh order to be issued within three months of remittance after reasonable opportunity; connected writ miscellaneous petitions closed; no order as to costs. ¶29

Sms Conveyors Vs The Deputy State Tax Officer 1 — Writ and Judicial Review | Madras HC (2026)

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WP No. 23663 of 2026

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IN THE HIGH COURT OF JUDICATURE AT MADRAS

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DATED: 02-07-2026

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CORAM

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THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY

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WP No. 23663 of 2026 and W.M.P.Nos.25619 & 25621 of 2026

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SMS Conveyors Rep by its Proprietor A Savitha SF No. 525, 526, Plots No. 498 and 486, Meenakshi Nagar Sipcot II, Samanapalli, Krishnagiri 635109

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..Petitioner(s)

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The Deputy State Tax Officer 1, Hosur (North 1) Assessment Circle, Survey No. 773 Anna Centenary Building, Ground Floor, Integrated commercial taxes offices Building, Seetharammedu, Hosur 635 109

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..Respondent(s)

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PRAYER : Writ Petition filed under Article 226 of The Constitution of India

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praying for the issuance of a Writ of Certiorari, calling for the records of the Respondent order dated 25.12.2025 with Reference No. ZD3312253845385 pertaining to the Financial Year 2021-22 and quash the same.

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For Petitioner(s): Mr.Raghunandan Sriram For Respondent(s): Mr.R.Sethu Prabakaran, Government Counsel (Tax)

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__________ Page1 of 4

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

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WP No. 23663 of 2026

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ORDER

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An order dated 25.12.2025 is assailed on the ground that the petitioner

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did not have a reasonable opportunity to contest the tax demand on merits.

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Mr.R.Sethu Prabakaran, learned Government Counsel (Tax), accepts notice on behalf of the respondent.

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On perusal of the impugned order, it is evident that such order was issued without hearing the petitioner. The writ petition has been filed after the period of limitation expired.

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On instructions, learned counsel for the petitioner agrees to remit 25% of the disputed tax demand as a condition for remand. An endorsement to that effect has been made on the bundle.

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Subject to the condition that the petitioner remits 25% of the disputed tax demand 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.

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__________ Page2 of 4

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

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WP No. 23663 of 2026

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

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costs.

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02-07-2026

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Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To

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The Deputy State Tax Officer 1, Hosur (North 1) Assessment Circle, Survey No. 773 Anna Centenary Building, Ground Floor, Integrated commercial taxes offices Building, Seetharammedu, Hosur 635 109

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__________ Page3 of 4

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

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WP No. 23663 of 2026

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SENTHILKUMAR RAMAMOORTHY, J.

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RNA

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WP No. 23663 of 2026 and W.M.P.Nos.25619 & 25621 of 2026