Tvl. Mugavai Traditional Crop Producer Company Limited vs. The Deputy State Tax Officer

This Writ Petition is taken up for final hearing at the time of admission with the consent of the learned counsel for the petitioner and learned Special Government Pleader for the respondent.

In this Writ Petition, the petitioner has challenged the Impugned Order of the respondent, dated 27.11.2025 bearing reference in GSTIN:33AAPCA4095F2ZK/2021-22. 4. The Impugned Order was preceded by a Show Cause Notice in GST DRC 01 dated 27.09.2025, and the petitioner has not filed his reply and the petitioner had not been provided an opportunity to submit documents to substantiate the same and thus, suffered the Impugned Order dated 27.11.2025. 5. It is noticed that the limitation for filing an appeal under Section 107 of the respective GST enactments, 2017 against the Impugned Order has already expired. The present Writ Petition has been filed only on 31.07.2026. https://www.mhc.tn.gov.in/judis __________ Page3 of 5

At this stage, the learned counsel for the petitioner submits that 12.5% of the disputed tax already recovered by the respondent. However, the petitioner is willing to pre-deposit 12.5% of the disputed tax as a condition for de novo adjudication, subject to the verification of the amount already recovered.

The learned counsel for the petitioner has also made an endorsement to that effect in the Court Bundle, which is extracted hereunder:- “The petitioner is ready to pay at 12.5% of the disputed tax and already paid 12.5% of the disputed tax on 25.03.2026.”

In view of the above, the impugned order is quashed and the case is remitted back to the respondent to pass a fresh order subject to the petitioner depositing 25% of the disputed tax in cash 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, subject to any payment made already shall be adjusted to aforesaid pre-deposit.

Within such time, the petitioner shall also file a reply to the Show Cause Notice in DRC 01 dated 27.09.2025 together with requisite documents to substantiate the case by treating the Impugned Order dated 27.11.2025 as an addendum to the Show Cause Notice dated 27.09.2025. https://www.mhc.tn.gov.in/judis __________ Page4 of 5

In case the petitioner complies with the above stipulations, the 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.

In case the petitioner fails to comply with any of the stipulations, the respondent is at liberty to proceed against the petitioner to recover the tax in accordance with law as if this Writ Petition was dismissed in limine today.

Needless to state, before passing any such order, the respondent shall give due notice to the petitioner.

This Writ Petition stands disposed of, with the above observations. No costs. Consequently, connected Writ Miscellaneous Petition is closed. 11-08-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No smn2 To The Deputy State Tax Officer Ramanathapuram Assessment Circle, Commercial Tax Office Buildings, Ramanathapuram District. https://www.mhc.tn.gov.in/judis __________ Page5 of 5 C.SARAVANAN, J. smn2 11-08-2026 https://www.mhc.tn.gov.in/judis