Sevvel Agency Vs Deputy State Tax Officer 1 Fac — Writ and Judicial Review | Madras HC (2026)

Sevvel Agency Vs Deputy State Tax Officer 1 Fac — Writ and Judicial Review | Madras HC (2026)

What the court decided

AI extract

Outcome

Impugned order dated 22.02.2025 set aside (subject to verification/confirmation of recovery of the tax demand) to enable the petitioner to appear for a personal hearing and contest the matter on merits; matter remanded for reconsideration with a fresh order to be issued within three months of confirming recovery; bank attachment to be raised upon such confirmation; writ petition disposed of without costs and connected WMP Nos. 28357 and 28425 of 2026 closed.

Issue for consideration

Whether the impugned assessment order dated 22.02.2025 (with consequential DRC-07) should be set aside because a personal hearing was not provided to the petitioner. +1 more

Court's answer

Subject to verification and confirmation that the tax demand was recovered, the impugned order is set aside so as to provide the petitioner an opportunity to appear for a personal hearing and contest the matter on merits.

Ratio / Principle

The matter is remanded for reconsideration; after providing a reasonable opportunity to the petitioner, a fresh order shall be issued within three months from the date of verifying and confirming the recovery of the tax demand.

Key takeaways

Subject to confirmation of the recovery of the tax demand, the bank attachment shall be raised.ratio¶21

Detailed headnote1 paragraphs

Madras High Court (Senthilkumar Ramamoorthy, J.), WP No. 25975 of 2026 and WMP Nos. 28357 and 28425 of 2026, decided 17-07-2026. Sevvel Agency, rep. by its Proprietor Mrs. Mani Selvarani v Deputy State Tax Officer 1 Fac, Nanganallur Assessment Circle. An assessment order dated 22.02.2025 and its consequential DRC-07 dated 22.02.2025 (Reference No. ZD330225233156S) were assailed under Article 226 of the Constitution primarily on the ground that a personal hearing was not provided to the petitioner. Counsel for the petitioner submitted that the entire tax demand under the impugned order had been recovered (paper book pages 84-85), an aspect the Court required to be verified and confirmed. Subject to such confirmation, the Court set aside the impugned order so as to provide the petitioner an opportunity to appear for a personal hearing and contest the matter on merits, remanded the matter for reconsideration with a fresh order to be issued within three months of verifying and confirming the recovery, and directed that the bank attachment be raised upon such confirmation. The writ petition stood disposed of without costs and the connected miscellaneous petitions were closed.

WP No. 25975 of 2026

IN THE HIGH COURT OF JUDICATURE AT MADRAS

DATED: 17-07-2026

CORAM

THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY

WP No. 25975 of 2026 and WMP Nos.28357 and 28425 of 2026

Sevvel Agency Rep by its Proprietor Mrs. MANI SELVARANI, Ground Floor, No.1, KESARI NAGAR, 5TH STREET, ADAMBAKKAM, Kancheepuram, Tamil Nadu - 600088 Vs Deputy State Tax Officer 1 Fac Nanganallur Assessment Circle, Room no 224, 2nd Floor, Anna Salai, Nandanam, Chennai 35

..Petitioner(s)

..Respondent(s)

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 Assessment ORDER dated 22.02.2025 and its consequential DRC -07 dated 22.02.2025 vide Reference No. ZD330225233156S issued by the Respondent and quash the same as arbitrary.

For Petitioner(s): Mr.A Abdul Rahman For Respondent(s): Ms.Amirta Dinakaran Government Counsel (Tax)

ORDER

Order dated 22.02.2025 is assailed primarily on the ground that a personal hearing was not provided to the petitioner.

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WP No. 25975 of 2026

2.Ms.Amirta, learned Government Counsel (Tax), accepts notice for the respondent.

3.Learned counsel for the petitioner submits that the entire tax demand

under the impugned order was recovered. He draws reference to the document at Pages 84 and 85 of the paper book in support. This aspect is required to be verified and confirmed.

4.Subject to verifying and confirming that the tax demand was recovered, the impugned order is set aside so as to provide an opportunity to the petitioner to appear for a personal hearing and contest the matter on merits.

5.Towards that end, the matter is remanded for reconsideration. After providing a reasonable opportunity to the petitioner, a fresh order shall be issued within three (3) months from the date of verifying and confirming the recovery of the tax demand. Subject to such confirmation, the bank attachment shall be raised.

6.In the result, the Writ Petition stands disposed of. No costs. Consequently, connected miscellaneous petitions are closed.

17-07-2026

KAS

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WP No. 25975 of 2026

To

Deputy State Tax Officer 1 Fac Nanganallur Assessment Circle, Room no 224, 2nd Floor, Anna Salai, Nandanam, Chennai 35

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WP No. 25975 of 2026

SENTHILKUMAR RAMAMOORTHY, J.

KAS

WP No. 25975 of 2026 and WMP Nos.28357 and 28425 of 2026

17-07-2026

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WP No. 25975 of 2026

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