M/S. K R K Marketing vs. Joint Commissioner

Original PDF →
WP/35748/2025HC KarnatakaGSTCNR KAHC01076205202508 December 2025Bench: S.R.KRISHNA KUMAR4 pages
For Petitioner: SMT. VEENA J. KAMATH, ADVOCATE FOR SRI. K. GOVINDARAYA KAMATH, ADVOCATEFor Respondent: SMT. JYOTI M. MARADI, HCGP

No AI summary yet for this judgment.

Cause title — parties, addresses and appearances
- 1 - HC-KAR NC: 2025:KHC:51957 WP No. 35748 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 8TH DAY OF DECEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO.35748 OF 2025 (T-RES) BETWEEN: M/S. K R K MARKETING NO.41, 42, 43 AND 44, SHOP NO.3, C.R.N. MARKET, GONDIPANTH STREET, BENGALURU – 560 002, A PARTNERSHIP FIRM REPRESENTED BY ITS PARTNER, SRI. K.R. ABDUL MALICK, (PARTNERSHIP FIRM) …PETITIONER (BY SMT. VEENA J. KAMATH, ADVOCATE FOR SRI. K. GOVINDARAYA KAMATH, ADVOCATE) AND: 1. JOINT COMMISSIONER OF COMMERCIAL TAXES (APPEALS)-3 2ND FLOOR, BMTC COMPLEX, K.H.ROAD, SHANTINAGAR, BENGALURU – 560 027. 2. COMMERCIAL TAX OFFICER (AUDIT)-3.6, DGSTO-03, ROOM NO.22, 1ST FLOOR, BMTC BUILDING, 4TH BLOCK, JAYANAGAR, BENGALURU – 560 011. …RESPONDENTS (BY SMT. JYOTI M. MARADI, HCGP) THIS W.P. IS FILED UNDER ARTICLES 226 & 227 OF THE CONSTITUTION OF INDIA PRAYING TO SET ASIDE THE IMPUGNED ORDER DATED 30/06/2025 BEARING NO.JCCT (APPEALS)-3/T.NO. 496/2024-25 PASSED BY THE R1 UNDER SECTION 107(4) OF THE GST Digitally signed by MADHURI S Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:51957 WP No. 35748 of 2025 ACT, 2017 FLOUTING THE PRINCIPLES OF NATURAL JUSTICE AT ANNX-A BY ISSUING A WRIT OF CERTIRORI, AND DIRECT THE R1 TO RESTORE AND ADMIT THE APPEAL FILED BY THE PETITIONER AGAINST THE RECTIFICATION ORDER DATED 31/01/2025 OF THE R2 ORDER PASSED IN CTO(A)-3.6/T.NO.418/2024-25 AT ANNEXURE-A1 AND HEAR IT ON ITS MERITS, BY ISSUING A WRIT OF MANDAMUS. THIS PETITION, COMING ON FOR PRELIMINARY HEARING IN ‘B’ GROUP, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR

ORAL ORDER

In this petition, petitioner seeks the following reliefs:

“a) Set aside the impugned order dated 30.06.2025 bearing No.JCCT (Appeals)-3/T.No.496/2024-25 passed by the 1st respondent under Section 107(4) of the GST Act, 2017 flouting the principles of natural justice at Annexure-A by issuing a Writ of Certiorari and direct the 1st respondent to restore and admit the appeal filed by the petitioner against the rectification order dated 31.01.2025 of the 2nd respondent order passed in CTO(A)- 3.6/T.No.418/2024-25 at Annexure-A1 and hear it on its merits, by issuing a writ of mandamus;

b) Grant any other relief or reliefs as this Hon’ble Court deems fit in the facts and circumstances of present case, in the interest of justice and equity.”

2.

Heard learned counsel for the petitioner and learned HCGP for the respondents and perused the material on record. HC-KAR NC: 2025:KHC:51957

3.

A perusal of the material on record will indicate that aggrieved by the adjudication order dated 28.08.2024, the petitioner filed a rectification application, which was partially allowed vide order dated 31.01.2025 and communicated to the petitioner on 24.02.2025. Aggrieved by the rectification order to the extent that it rejected the claim of the petitioner partially, the petitioner filed an appeal on 14.03.2025, which was dismissed summarily by the First Appellate Authority vide impugned order dated 30.06.2025 on the ground that the appeal was barred by limitation. In this context, a perusal of the impugned order will indicate that respondent No.1 – Appellate Authority has miscalculated the period of limitation without appreciating that the material on record clearly indicated that appeal was well within limitation / within the meaning of Section 107(1) and 107(4) of the KGST Act warranting interference by this Court in the present petition.

4.

In the result, I pass the following: ORDER

(i) The petition is hereby allowed. HC-KAR NC: 2025:KHC:51957 (ii) The impugned order at Annexure – A dated 30.06.2025 passed by respondent No.1 is hereby set aside.

(iii)

The appeal filed by the petitioner before the respondent No.1 – Appellate Authority is held to be within limitation / time and not barred by limitation as wrongly held by the Appellate Authority. (iv) Matter is remitted back to respondent No.1 – Appellate Authority for reconsideration on merits and without reference to the period of limitation which stands concluded in favour of the petitioner by this order. (S.R.KRISHNA KUMAR) JUDGE

SV List No.: 2 Sl No.: 127

Reproduced from the public record of the Karnataka High Court. Verify against the court's own copy before relying on it. Income tax judgments are on bharattax.net.