Galore Networks Private Ltd vs The Assistant Commissioner ST

WP Nos. 43113, 43144 and 43129 of 2026
IN THE HIGH COURT OF JUDICATURE AT MADRAS
DATED: 16-10-2026
CORAM
THE HON'BLE MR JUSTICE KRISHNAN RAMASAMY
WP Nos. 43113, 43144 and 43129 of 2026
and
WMP Nos.48432, 48437, 48441, 48469, 48471, 48477,
48481, 48453, 48454, 48455 of 2026
CNR:{HCMA012518722026}
W.P.No.43113 and 43129 of 2026
Galore Networks Private Ltd,
Represented by its Director M. Raju
L 1, RAM, Industrial Estate, Guindy,
Chennai, Tamil Nadu 600 032
Currently at
th
Plot No. 33B, 9 Floor, Olympia Platina,
Lazar Street, Chennai,
Tamil Nadu-600 032
..Petitioners
Vs
1. The Assistant Commissioner ST
Guindy Assessment Circle, South II,
nd
No. 255, 2 Floor, Integrated
Commercial Taxes and Registration
Department Building,
Nandanam, Chennai, Tamil
Nadu-600 035.
2. The Branch Manager
Kotak Mahindra Bank
87-148, Mayur Greens,
Bengaluru, Karnataka-560034.
..Respondents
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WP Nos. 43113, 43144 and 43129 of 2026
WP No. 43144 of 2026
CNR:{HCMA012518782026}
1. M. Raju
S/o Malayappan, aged about 53 years,
Director, Galore Networks Private Ltd .
Plot No. 33B, 9th Floor, Olympia Platina,
Lazar Street, Chennai, Tamil Nadu - 600 032
2. K Balaji
S/o Kulothungan, aged about 49 years, Director,
Galore Networks Private Ltd. Plot No. 33B, 9th
Floor, Olympia Platina,Lazar Street, Chennai,
Tamil Nadu
3. Kotak Mahindra Bank 87-148, Mayur
Greens,Bengaluru, Karnataka
S/o Kulothungan, aged about 49 years,
Director, Galore Networks Private Ltd.
Plot No. 33B, 9th Floor, Olympia Platina,
Lazar Street, Chennai, Tamil Nadu - 600 032
..Petitioner(s)
Vs
1. The Assistant Commissioner (ST)
Guindy Assessment Circle, South II,
nd
No. 255, 2 Floor,
Integrated Commercial Taxes and Registration
Department Building,
Nandanam, Chennai, Tamil Nadu-600 035.
2. The Branch Manager
Axis Bank Ltd. 225,
Opposite Spencers Plaza,
Anna Salai, Chennai, Tamil Nadu - 600 002
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WP Nos. 43113, 43144 and 43129 of 2026
3. The Branch Manager
Kotak Mahindra Bank Plot No. 10, Ground Floor,
T S S ManoreArcot Road, Lakshmi Nagar, Porur,
Chennai, Tamil Nadu
4. The Branch Manager
Kotak Mahindra Bank 359/39 Bren Mercury,
Koikondrahalli,Sarjapur Main Road, Bengaluru,
Karnataka
5. The Branch Manager
Axis Bank Ltd. NIFT Campus, Site No. 21, 27th
Main HSR Layout Sector 1, Bangalore
6. The Branch Manager
rd
DBS BANK LTD 3 Floor, Fort House,
221, Dr D.N. Road, Fort Mumbai
..Respondent(s)
PRAYER in WP No. 43113 of 2026 : The Writ Petition is filed under Article
226 of the Constitution of India seeking the issuance of a Writ of Certiorarified
Mandamus calling upon the records of the impugned order issued by the 1st
Respondent bearing GSTIN 33AAFCG4151N1ZJ/2020-21 and Order and
Summary of Order in Reference No. ZD331224139170Y, both dated
17.12.2024 and the consequential impugned attachment notice issued by the 1st
Respondent bearing GSTIN 33AAFCG4151N1ZJ/2017-18 to 2021-22 dated
25.09.2026, quash the same and consequently remand the matter to the 1st
Respondent directing them to entertain the records, documents and reply from
the Petitioner and then pass order after affording a personal hearing to the
Petitioner.
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WP Nos. 43113, 43144 and 43129 of 2026
PRAYER in WP No. 43129 of 2026 : The Writ Petition is filed under Article
226 of the Constitution of India seeking the issuance of a Writ of Certiorarified
Mandamus calling upon the records of the impugned order issued by the 1st
Respondent bearing GSTIN 33AAFCG4151N1ZJ/2020-21 and Order and
Summary of Order in Reference No. ZD331124111866N, both dated
15.11.2024 and the consequential impugned attachment notice issued by the 1st
Respondent bearing GSTIN 33AAFCG4151N1ZJ/2017-18 to 2021-22 dated
25.09.2026, quash the same and consequently remand the matter to the 1st
Respondent directing them to entertain the records, documents and reply from
the Petitioner and then pass order after affording a personal hearing to the
Petitioner.
PRAYER in WP No. 43144 of 2026 : The Writ Petition is filed under Article
226 of the Constitution of India seeking the issuance of a Writ of Certiorarified
Mandamus calling upon the records of the impugned attachment notice issued
by the 1st Respondent bearing GSTIN 33AAFCG4151N1ZJ/2017-18 to 2021-
22 dated 25.09.2026, quash the same and consequently direct the 1st
Respondent to lift the bank attachment issued to the 2nd to 6th Respondents in
relation to the Petitioners bank accounts bearing Acc. Nos. 168010100112994,
04680110002248, 2813535113, 911010047409361, 168010100113243 and
881003049462 pursuant to the impugned attachment notice issued by the 1st
Respondent bearing GSTIN 33AAFCG4151N1ZJ/2017-18 to 2021-22 dated
25.09.2026.
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WP Nos. 43113, 43144 and 43129 of 2026
For Petitioner(s):
in all W.Ps.
Mr. Baranidharan. U
For Respondent(s):
in all W.Ps.
Mr. R. Sethu Prabakaran
Government Advocate (Taxes) for R1
- - - - -
COMMON ORDER
The present Writ Petitions have been filed challenging the orders dated
15.11.2024, 17.12.2024 and 25.09.2026 passed by the first respondent.
2. The learned counsel for the petitioner submits that the orders
challenged in these Writ Petitions were passed ex-parte . He further submits that
the notices and communications in these cases were uploaded by the respondent
under the “View Additional Notices and Orders” tab on the GST common
portal. Since the petitioner was unaware of the said notices, they failed to file a
reply within the stipulated time. Under these circumstances, the impugned
orders were passed by the respondent without affording the petitioner an
opportunity for a personal hearing.
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WP Nos. 43113, 43144 and 43129 of 2026
3. In response, the learned Government Advocate (Taxes) appearing for
the first respondent fairly concedes that the impugned orders dated 15.11.2024
and 17.12.2024 were passed ex-parte . He states that regarding the impugned
order dated 25.09.2026, a total of eight orders were passed, out of which two
have been challenged in W.P. No. 43144 of 2026, and the remaining six are
pending.
4. At this juncture, the learned counsel for the petitioner submits that the
petitioner is willing to voluntarily deposit 20% of the disputed tax amount with
the first respondent. To that effect, he has also made an endorsement in the
Court bundles. Hence, he requests this Court to set aside the impugned orders
and grant the petitioner an opportunity to present their case before the first
respondent. He further clarifies that out of the remaining six orders, two have
already been challenged before this Court by way of separate Writ Petitions,
which are currently pending at the SR stage, and the petitioner is willing to
deposit 20% of the disputed tax amount for those petitions as well. As for the
remaining four unchallenged orders, the petitioner agrees to pay the tax amount
in full.
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WP Nos. 43113, 43144 and 43129 of 2026
5. Heard the learned counsel for the petitioner and the learned
Government Advocate (Taxes) for the first respondent and also perused the
materials available on record.
6. In the case on hand, it is evident that the show cause notices were
uploaded on the GST Portal Tab. According to the petitioner, he was not aware
of the issuance of the said show cause notice issued through the GST Portal and
the original of the said show cause notices were not furnished to them. In such
circumstances, this Court is of the view that the impugned assessment orders
came to be passed without affording any opportunity of personal hearing to the
petitioner, confirming the proposals contained in the show cause notice.
7. No doubt, sending notice by uploading in portal is a sufficient service,
but, the Officer who is sending the repeated reminders, despite the fact that
there is no response from the petitioner to the show cause notices etc., should
have applied his/her mind and explored the possibility of sending notices by
way of other modes prescribed in Section 169 of the GST Act, which are also
the valid mode of service under the Act, otherwise it will not be an effective
service, rather, it would only amount to fulfilling the empty formalities. Merely
passing an ex parte order by fulfilling the empty formalities will not serve any
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WP Nos. 43113, 43144 and 43129 of 2026
useful purpose and the same will only pave way for multiplicity of litigations,
not only wasting the time of the Officer concerned, but also the precious time of
the Appellate Authority/Tribunal and this Court as well.
8. Thus, when there is no response from the tax payer to the notice sent
through a particular mode, the Officer who is issuing notices should strictly
explore the possibilities of sending notices through some other mode as
prescribed in Section 169(1) of the Act, preferably by way of RPAD, which
would ultimately achieve the object of the GST Act. Therefore, this Court finds
that there has been a lack of effort in applying the available opportunities to
serve the notices/orders etc., effectively to the petitioner.
9. Further, it was submitted by the learned counsel for the petitioner that
the petitioner is willing to pay 20% of the disputed tax amount to the first
respondent. In such view of the matter, this Court is inclined to set aside the
impugned orders passed by the first respondent. Accordingly, this Court passes
the following order:-
(i) The impugned orders dated 15.11.2024, 17.12.2024
and 25.09.2026 are set aside and the matters are remanded to
the first respondent for fresh consideration on condition that
the petitioner pays 20% of disputed tax amount to the first
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WP Nos. 43113, 43144 and 43129 of 2026
respondent, in respect of each impugned order, within a
period of four (4) weeks from the date of receipt of a copy of
this order. The setting aside of the impugned orders will take
effect from the date of payment of the said amount. In the
event, any amount is already recovered or deposited, the
petitioner is granted liberty to adjust the said amount while
making payment of 20% of the disputed tax amount.
(ii) The petitioner shall file their reply/objection along
with the required documents, if any, within a period of four
weeks from the date of payment of amount as stated above.
(iii) On filing of such reply/objection by the petitioner,
the first respondent shall consider the same and issue a 14
days clear notice, by fixing the date of personal hearing, to the
petitioner and thereafter, pass appropriate orders on merits and
in accordance with law, after hearing the petitioner, as
expeditiously as possible.
(iv) Considering the fact that the impugned orders
itself have been set aside, this Court is of the opinion that the
attachment made on the bank account of the petitioners,
cannot survive any longer and hence, it is to be lifted. As a
sequel, the concerned Banks are directed to release the
attachment, and de-freeze the bank accounts of the petitioner,
immediately upon proof of payment of the said amount.
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WP Nos. 43113, 43144 and 43129 of 2026
10. With the above directions, these Writ Petitions are disposed of. No
costs. W.M.P.Nos.48432, 48471 and 48453 of 2026 filed to dispense with the
production of the original impugned orders, are allowed. W.M.P.No.48469 of
2026, filed to permit the petitioners in W.P.No.43144 of 2026, to file a single
Writ Petition, is allowed subject to the payment of separate Court fees.
Consequently, the connected Miscellaneous Petitions are also closed.
16-10-2026
Note: Issue order copy on 16.10.2026
Asi
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WP Nos. 43113, 43144 and 43129 of 2026
To
1. The Assistant Commissioner (ST)
Guindy Assessment Circle, South II,
No. 255, 2nd Floor,
Integrated Commercial Taxes and Registration
Department Building,
Nandanam, Chennai, Tamil Nadu-600 035.
2. The Branch Manager
Kotak Mahindra Bank 87-148, Mayur Greens,
Bengaluru, Karnataka.
3. The Branch Manager
Axis Bank Ltd. 225,
Opposite Spencers Plaza,
Anna Salai, Chennai, Tamil Nadu - 600 002
4. The Branch Manager
Kotak Mahindra Bank Plot No. 10, Ground Floor,
T S S Manore Arcot Road, Lakshmi Nagar, Porur,
Chennai, Tamil Nadu

5. The Branch Manager
Kotak Mahindra Bank 359/39 Bren Mercury,
Koikondrahalli,Sarjapur Main Road, Bengaluru,
Karnataka
6. The Branch Manager,
Axis Bank Ltd. NIFT Campus, Site No. 21,
th
27 Main HSR Layout Sector 1, Bangalore
7. The Branch Manager
rd
DBS BANK LTD 3 Floor, Fort House,
221 Dr D.N. Road, Fort Mumbai
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WP Nos. 43113, 43144 and 43129 of 2026
cKRISHNAN RAMASAMY J.
Asi
WP Nos. 43113, 43144 and 43129 of 2026 and
WMP Nos.48432, 48437, 48441, 48469, 48471, 48477,
48481, 48453, 48454 and 48455 of 2026
16-10-2026
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