Procedural Fairness Reaffirmed

This note by J the app, examines the decision of the Madurai Bench of the Madras High Court in W.P.(MD) No. 3241 of 2026, dated 09.02.2026, concerning an assessment under Section 73 of the TNGST Act, 2017. The case raises fundamental issues relating to service of notice, opportunity of hearing, procedural fairness, and the legality of coercive recovery including bank attachment. The judgment is significant as it reinforces a foundational principle: tax administration must be procedurally just. Even in a regime driven by electronic communication and portal-based compliance, effective service and meaningful opportunity cannot be reduced to technical formality.