Smt Hassan Laxman Rao Vidya vs. Assistant Commissioner Of Commercial Taxes

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WP/25194/2024HC KarnatakaGSTCNR KAHC01052068202417 November 2025Bench: S.R.KRISHNA KUMAR7 pages
For Petitioner: SRI. ABHIJITH S. BAPU AND SRI. SHREEHARI KUTSA, ADVOCATESFor Respondent: SRI. HEMA KUMAR K., AGA FOR R1 TO R6; SRI. NANDISH PATIL, ADVOCATE FOR R7

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Cause title — parties, addresses and appearances
- 1 - HC-KAR NC: 2025:KHC:47489 WP No. 25194 of 2024 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 17TH DAY OF NOVEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 25194 OF 2024 (T-RES) BETWEEN: SMT. HASSAN LAXMAN RAO VIDYA PROPRIETOR, M/S ANURGRAHA ENTERPRISES, D/O OF HASSAN LAXMAN RAO, AGED ABOUT 42 YEARS SHASHI DARSHINI, 49/2 , IIIRD CROSS, VALLABAI ROAD, HASSAN – 573 201 …PETITIONER (BY SRI. ABHIJITH S. BAPU AND SRI. SHREEHARI KUTSA, ADVOCATES) AND: 1. ASSISTANT COMMISSIONER OF COMMERCIAL TAXES (AUDIT-1), LGSTO-240, SUVARNA KARNATAKA VANIJYA THERIGE BHAVAN, GOPAL GOWDA EXTENSION, SHIMOGA – 577 201 2. ASSISTANT COMMISSIONER OF COMMERCIAL TAXES LGSTO- 240, SHARADA SAMUDAYA BHAVAN, SHANKARMUTT ROAD, HASSAN – 573 201 THE JURISDICTIONAL PROPER OFFICER UNDER THE CGST /KGST ACT 2017 3. COMMERCIAL TAX OFFICER, LGSTO - 240, HASSAN, SHARADA SAMUDAYA BHAVAN SHANKARMUTT ROAD, HASSAN – 573 201 Digitally signed by MADHURI S Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:47489 WP No. 25194 of 2024 4. ASSISTANT COMMISSIONER OF COMMERCIAL TAXES (ENFORCEMENT) -14, BENGALURU SOUTH ZONE, ‘B’ BLOCK, VTK- 2, NEW PASSPORT OFFICE, KORAMANGALA, BENGALURU – 560 047 5. JOINT COMMISSIONER OF COMMERICAL TAXES (ADMIN), SHIMOGA GST MALNAD DIVISION, SHIMOGA – 573 201 6. COMMISSIONER OF COMMERCIAL TAXES (KARNATAKA), BENGALURU VANIJYA THERIGE KARYALAYA 2, NEAR KHB GAMES VILLAGE, 80 FEET ROAD, KORAMANGALA, BENGALURU – 560 095 7. THE BRANCH MANAGER STATE BANK OF MYSORE 4TH BLOCK, RAJAJINAGAR BENGALURU – 560 010 …RESPONDENTS (BY SRI. HEMA KUMAR K., AGA FOR R1 TO R6; SRI. NANDISH PATIL, ADVOCATE FOR R7) THIS W.P. IS FILED UNDER ARTICLES 226 & 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE PROCEEDINGS UNDER RULE 86(A)(1) DATED 05.05.2022 BEARING VIDE ORDER NO. ACCT/LGSTO-240/HSN/ITC/BLOCK-04/2022-23 ISSUED BY RESPONDENT NO.2 AND ENCLOSED AS ANNEXURE-C AND ETC., THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR - 3 - HC-KAR NC: 2025:KHC:47489 WP No. 25194 of 2024

ORAL ORDER

In this petition, petitioner seeks for the following reliefs:- “A. Issue a writ of certiorari or any other suitable writ quashing the proceedings under Rule 86(A)(1) dated 05.05.2022 bearing vide ORDER NO. ACCT/ LGSTO- 240/HSN/ITC/BLOCK-04/2022-23 issued by Respondent No.2 and enclosed as Annexure C. B. Issue a writ of certiorari or any other suitable writ quashing the Show Cause Notice under section 29(2) dated 09/03/2022 bearing Ref.No.ZA290322027730T issued by Respondent No.2 and enclosed as Annexure D. C. Issue a writ of certiorari or any other suitable writ quashing the Order u/s 74(9) dated 27/09/2023 bearing File No. ACCT(Audit): Smg: T: 2023-24 along with DRC-07 bearing reference no.ZD2909230472066 for the tax period from July 2017-March 2018 issued by the Respondent No. 1 and enclosed as Annexure J1 and Annexure J2 respectively. D. And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity.”

2.

Heard the learned counsel for both parties and perused the material on record. HC-KAR NC: 2025:KHC:47489

3.

A perusal of the material on record will indicate that the petitioner was granted GST registration certificate on 01.07.20217. Pursuant to issuance of summons dated 22.10.2018, to which the petitioner filed a reply dated 21.12.2018, respondent No.2 issued a show-cause notice dated 09.03.2022 to which the petitioner did not submit any reply. Under these circumstances, respondent No.1 proceeded to pass the impugned exparte adjudication order dated 27.09.2023, aggrieved by which the petitioner is before this court by way of the present petition.

4.

It is a specific contention of the petitioner that he did not receive the aforesaid notices. Orders etc, and due to bonafide reasons, unavoidable circumstances and sufficient cause, the petitioner was not in a position to submit reply and contest the proceedings and as such, it is necessary that the impugned order dated 27.09.2023 is set aside and the matter be remitted back to the concerned respondent for reconsideration afresh to the stage of the petitioner submitting reply to the show cause notice and to proceed further in the matter. HC-KAR NC: 2025:KHC:47489

5.

Learned counsel for the petitioner submits that he would not press prayer (a) and (b) and the same is placed on record.

6.

Per contra learned AGA for respondent Nos.1 to 6 and learned counsel for respondent No.7 submits that there is no merit in the petition and that the same is liable to be dismissed.

7.

A perusal of the material on record will indicate that though several contentions have been urged by both sides in support of their respective claims, it is an undisputed fact and a matter of record that the petitioner did not submit any replies to the notices issued by the respondents nor did he participate in the impugned proceedings, which culminated in the impugned exparte adjudication order in the absence of the petitioner. Under these circumstances, in order to provide one more opportunity to the petitioner to submit reply to the show cause notice and contest the proceedings, I deem it just and appropriate to adopt justice oriented approach and set aside the impugned order at Annexure-J1 dated 27.09.2023 and remit the matter back to the respondent for HC-KAR NC: 2025:KHC:47489 reconsideration afresh to the stage of the petitioner submitting reply to the show cause notice

8.

In the result, I pass the following: ORDER i) The Writ Petition is allowed;

ii) The impugned order and the summary of the order, both dated 27.09.2023 passed by respondent No.1 at Annexures-J1 and J2 respectively, are hereby set aside; iii) The matter is remitted back to respondent No.1 for reconsideration afresh from the stage of the petitioner submitting its reply to show-cause notice dated 09.03.2022, in accordance with law. iv) The petitioner shall appear before the respondent on 15.12.2025, without awaiting further notice from the respondents, failing which the present order shall stand recalled automatically, without further reference to the Bench and without further orders. v) Liberty is reserved in favour of the petitioner to submit replies, responses, pleadings, documents etc., which shall be considered by the respondent, who shall provide sufficient and HC-KAR NC: 2025:KHC:47489 reasonable opportunity to the petitioner, hear him and proceed further, in accordance with law. vii) Further, in the light of the judgment of the Division Bench of this Court in the case of K-9- W.A.No.100425/2023 and connected matters, the respondents are hereby directed to unblock the electronic credit ledger of the petitioner, immediately, without any delay. (S.R.KRISHNA KUMAR) JUDGE

BMC List No.: 2 Sl No.: 28

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.