M/S. Camden Town Technologies (P) Limited vs. Assistant Commissioner Of Commercial Taxes - Karnataka High Court, 03 February 2026

Cause title — parties, addresses and appearances

- 1 - HC-KAR NC: 2026:KHC:6221 WP No. 2573 of 2026 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 3RD DAY OF FEBRUARY, 2026 BEFORE THE HON'BLE MR. JUSTICE S SUNIL DUTT YADAV WRIT PETITION NO. 2573 OF 2026 (T-RES) BETWEEN: M/S. CAMDEN TOWN TECHNOLOGIES (P) LIMITED MUNICIPAL NO.20, SITE NO.19 AND 20, INDIQUBE CELESTIA, GROUND AND THIRD FLOOR, SARJAPURA MAIN ROAD, KORAMANGALA J BLOCK, 23RD CROSS, BENGALURU - 560 034 REPRESENTED BY ITS DIRECTOR SRI. MOHIT CHHAJER, A PRIVATE LIMITED COMPANY REGISTERED UNDER THE COMPANIES ACT, 2013 …PETITIONER (BY SRI. K. GOVINDARAYA KAMATH, ADVOCATE) AND: 1. ASSISTANT COMMISSIONER OF COMMERCIAL TAXES, LGSTO-015, 6TH FLOOR, BMTC BUILDING, 6TH BLOCK, 80 FEET ROAD, KORAMANGALA, BENGALURU - 560 095 Digitally signed by VIJAYA P Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2026:KHC:6221 WP No. 2573 of 2026 2. GOVERNMENT OF KARNATAKA REPRESENTED BY UNDER SECRETARY TO GOVERNMENT FINANCE DEPARTMENT VIDHAN SOUDHA, BENGALURU - 560 001 3. UNION OF INDIA REPRESENTED BY THE SECRETARY, DEPARTMENT OF REVENUE MINISTRY OF FINANCE NORTH BLOCK, NEW DELHI - 110 001 …RESPONDENTS (BY SRI. K. HEMAKUMAR, AGA FOR R1 AND R2 SRI. MADANAN PILLAI, CGC FOR R3) THIS W.P. IS FILED UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO SET ASIDE THE IMPUGNED ORDER DATED 19.08.2024 PASSED BY THE 1ST RESPONDENT IN ACCT(P)/LGSTO-015/DRC.07/2024-25 FOR THE TAX PERIODS APRIL 2019 TO MARCH 2020 UNDER SECTION 73 OF THE GST ACT AT ANNEXURE-A, BY ISSUING A WRIT OF CERTIORARI OR ANY OTHER ORDER IN THE NATURE A WRIT OF CERTIORARI AND ETC. THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE S SUNIL DUTT YADAV - 3 - HC-KAR NC: 2026:KHC:6221 WP No. 2573 of 2026

ORAL ORDER

The petitioner has called in question the validity of the impugned order at Annexure-A which is an order passed under Section 73 of the KGST Act, 2017. 2. It is the case of the petitioner that the petitioner had made out a detailed reply clarifying the mis-match of ITC and the authority has merely observed in the impugned order, as follows; "The reply filed by the taxpayer does not address the specific concerns of the tax liabilities detailed in the show cause notice. Therefore, Taxable Person is hereby directed to make the payment of Tax/Interest/Penalty which are quantified as detailed below within thirty days from the date of receipt of this order."

Learned counsel for the petitioner submits that the response of the petitioner has been extracted in detail as a part of the impugned order that has not been adverted to.

Perused the order in original. The reply of the petitioner is extracted in the impugned order. However, it HC-KAR NC: 2026:KHC:6221 is noticed that the Assessing Officer despite having extracted the reply has not adverted to the assertions of the petitioner as regards attempted reconciliation. It could be stated that application of mind requires detailed reasoning in the order itself.

Taking note of the contentions advanced, petition is disposed of. The order at Annexure-A is set-aside. The matter is remitted back to respondent No.1 for fresh consideration with a specific observation that the reply made out by the petitioner extracted in the order of adjudication produced herein, ought to be re-looked into and the authority to apply its mind to the said stand of the petitioner.

Upon remand, while re-doing the assessment proceedings, the petitioner to appear without further notice on 23.02.2026, on which date, the Authority may afford an opportunity of personal hearing.

All contentions are kept open. HC-KAR NC: 2026:KHC:6221

In view of disposal of the petition, I.A.No.1/2026 does not survive for consideration. Accordingly, the same is disposed of. (S SUNIL DUTT YADAV) JUDGE GH List No.: 2 Sl No.: 35