(Common Prayer: Writ Petitions filed under Article 226 of the Constitution of India for issuance of Writ of Certiorari, calling for the entire records connected with the Impugned Order of the first respondent and his proceedings in Ref.No. ZD330325144246N dated 19.03.2025 in GSTIN 33CYCPP8757M1ZP/2021-2022 and Ref.No. ZD331125068405L dated 05.11.2025 in GSTIN 33CYCPP8757M1ZP/2021-2022, respectively, and quash the same and consequently, direct the second respondent to defreeze the petitioner’s Bank Account.)
Common Order:
1. M/s.P.Sudarkodi Natchiyar, learned Government Advocate (Tax), takes notice for the first respondent.
2. These Writ Petitions are taken up for final hearing at the time of admission with the consent of the learned counsel for the petitioner and learned Government Advocate (Tax) for the first respondent.
3. In this Writ Petition, the petitioner has challenged the respective impugned Assessment Orders as detailed below:
| S.No. | W.P.(MD) Nos. | Date | Assessment Year | Tax amount | Late fee |
| 1. | 21748/2026 | 19.03.2025 | 2021-22 | Rs.5,64,500/- x 2 | Nil |
| 2. | 21750/2026 | 05.11.2025 | 2021-22 | Rs.5,64,500/- x 2 | Rs.2,050/- |
5. At this stage, the learned counsel for the petitioner submits that the petitioner is willing to pre-deposit 25% of the disputed tax as confirmed in the Impugned Order dated 19.03.2025 as a condition for de novo adjudication.
6. The learned counsel for the petitioner has also made an endorsement to that effect in the Court Bundle, which is extracted hereunder:-
“I undertake, on behalf of my client, to deposit 25% of the demand amount. To that effect this endorsement is made.”
7. In view of the above, the impugned orders are quashed and the cases are remitted back to the first 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, as confirmed vide Impugned order dated 19.03.2025.
8. Within such time, the petitioner shall also file a consolidated reply to the respective Show Cause Notices in DRC 01 dated 18.06.2024 and 26.08.2025, together with requisite documents to substantiate the case by treating the Impugned Orders dated 19.03.2025 and 05.11.2025 as an addendum to the respective Show Cause Notices dated dated 18.06.2024 and 26.08.2025.
9. In case the petitioner complies with the above stipulations, the first 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. Subject to the petitioner complying with the above stipulations, the attachment of the bank account of the petitioner shall also stand automatically vacated.
10. It is made clear that bank attachment shall be lifted subject to the deposit of 25% of the disputed tax as ordered above and the petitioner not being in arrears of any other amount for any other tax period barring the amount demanded under the impugned Order.
11. In case the petitioner fails to comply with any of the stipulations, the respondents are 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.
12. Needless to state, before passing any such order, the first respondent shall give due notice to the petitioner.
13. These Writ Petitions stand disposed of, with the above observations. No costs. Consequently, connected Writ Miscellaneous Petitions are closed.