Conviva Apac Private Limited vs. The Assistant Commissioner

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WP/30443/2025HC KarnatakaGSTCNR KAHC01065118202513 November 2025Bench: S.R.KRISHNA KUMAR5 pages
For Petitioner: SMT. ANANYA KAPOOR., ADVOCATE FOR SRI. ANKUR PAI DHUNGAT., ADVOCATEFor Respondent: SRI. ARAVIOND V CHAVAN., ADVOCATE

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Cause title — parties, addresses and appearances
- 1 - HC-KAR NC: 2025:KHC:46300 WP No. 30443 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 13TH DAY OF NOVEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 30443 OF 2025 (T-RES) BETWEEN: CONVIVA APAC PRIVATE LIMITED 1ST FLOOR, BLOCK B, SURVEY NO. 125 AND 132/1, 77 TOWN CENTRE, AMANI BELLANDUR KHANE VILLAGE, VARTHUR HOBLI, BENGALURU 560037. A COMPANY INCORPORATED UNDER THE COMPANIES ACT, 1956 AND REPRESENTED BY ITS DIRECTOR MS. DEEPTI LAVINA LEWIS D/O BONIFAS LEWIS, AGED ABOUT 46 YEARS, OCC: DIRECTOR RESIDING AT F-0222, BRIGADE LAKE FRONT, NEXT TO SAP LABS EPIP ZONE, WHITEFIELD, BENGALURU -560048. …PETITIONER (BY SMT. ANANYA KAPOOR., ADVOCATE FOR SRI. ANKUR PAI DHUNGAT., ADVOCATE) AND: THE ASSISTANT COMMISSIONER BANGALORE EAST DIVISION Digitally signed by JUANITA THEJESWINI Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2025:KHC:46300 WP No. 30443 of 2025 6TH FLOOR, GST COMMISSIONERATE 2, TTMC, BMTC BUS STAND COMPLEX, HAL OLD AIRPORT ROAD, DOMLUR, BENGALURU- 560007. …RESPONDENT (BY SRI. ARAVIOND V CHAVAN., ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 & 227 OF THE CONSTITUTION OF INDIA PRAYING TO ISSUE THE WRIT OF MANDAMUS OR ANY OTHER APPROPRIATE WRIT IN THE NATURE OF MANDAMUS WRIT, ORDER OR DIRECTION DIRECTING RESPONDENT TO ADJUDICATE THE REFUND APPLICATIONS FILED BY THE PETITIONER ON 30.06.2025 (ANNEXURE 'C1') FOR THE FY 2023- 24 AND CONSEQUENTLY ISSUE THE REFUND OF RS.95,57,797/- ALONG WITH INTEREST AND ETC. THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR

ORAL ORDER

In this petition, the petitioner seeks the following reliefs:

"i. To issue the writ of mandamus or any other appropriate writ in the nature of mandamus writ, order or direction directing Respondent to adjudicate the refund applications filed by the Petitioner on 30.06.2025 (ANNEXURE 'C5') for the FY 2023- 24 and consequently issue the refund of Rs.95,57,797/- along with interest. HC-KAR NC: 2025:KHC:46300 ii. To issue any other order(s), direction(s), writ(s) or any other relief(s) as this Hon'ble Court deems fit and proper in the facts and circumstances of the case and in the interest of justice."

2.

Heard learned Counsel for the petitioner and learned Counsel for the respondent and perused the material on record.

3.

Learned Counsel for the petitioner would invite my attention to the memorandum of writ petition and the documents produced along with the petition in order to point out that on 27.03.2025 vide Annexure 'A', the petitioner filed refund application in Form GST RFD-01 before the respondent along with all the relevant /supporting documents, despite which the respondent issued a cryptic, non-speaking deficiency memo dated 28.03.2025 vide Annexure 'B', as a result of which the petitioner submitted one more application, on the very same day, i.e., 28.03.2025 vide Annexure 'C' to which the respondent issued one more deficiency memo vide Annexure 'D' dated 01.04.2025, in pursuance of which the petitioner filed one more application on 02.04.2025 vide Annexure 'C1', to which the respondent yet again issued a cryptic HC-KAR NC: 2025:KHC:46300 deficiency memo stating that the petitioner had not submitted supporting documents. It is submitted that as a result of the complete/ total inaction on the part of the respondent who repeatedly intimated the petitioner that the supporting documents had not been furnished by them, the petitioner reiterated its claim vide Annexures 'C2', 'C3', 'C4' and 'C5' despite which the respondent has not taken steps to consider the refund claims/ applications of the petitioner who is before this Court by way of the present petition.

4.

Per contra, learned counsel for the respondent submits that if reasonable time is granted, the respondent would consider the refund claim of the petitioner and take appropriate decision / pass appropriate orders in accordance with law.

5.

In view of the aforesaid facts and circumstances, I deem it just and appropriate to dispose of this petition directing the respondent to consider the refund claims of the petitioner and take appropriate decision/ pass appropriate orders in accordance with law, after providing sufficient and reasonable opportunity to the petitioner as expeditiously as possible, at any rate, within a stipulated timeframe. HC-KAR NC: 2025:KHC:46300

6.

In order to enable the respondent to consider the claims of the petitioner as stated supra, the petitioner is directed to appear before the respondent on 24th November 2025 at 11.00 a.m. on which date the petitioner is at liberty to produce additional pleadings/documents which shall be considered by the respondent, who shall consider the same and take appropriate decision/ pass appropriate orders within a period of two months from 24th November 2025. 7. Subject to the aforesaid directions, the writ petition stands disposed of. (S.R.KRISHNA KUMAR) JUDGE

JT/- CT: JL

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.