M/S Ma Agency vs. Union Of INDIA

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WP/105123/2024HC KarnatakaGSTCNR KAHC02012865202423 September 2025Bench: SURAJ GOVINDARAJ5 pages
For Petitioner: SRI. GAYATRI S.R., ADVOCATEFor Respondent: SRI. M.B. KANAVI, CGSE FOR R1; SRI. GIRISH S. HULAMANI, ADVOCATE FOR R2; SRI. SHARAD V. MAGADUM, AGA FOR R3 TO R6

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Cause title — parties, addresses and appearances
- 1 - HC-KAR NC: 2025:KHC-D:12989 WP No. 105123 of 2024 IN THE HIGH COURT OF KARNATAKA,AT DHARWAD DATED THIS THE 23RD DAY OF SEPTEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE SURAJ GOVINDARAJ WRIT PETITION NO. 105123 OF 2024 (T-RES) BETWEEN: M/S. MA AGENCY LOCATED AT 2078, TRICHY ROAD, SINGANALLUR, COIMBATORE, TAMIL NADU-641006. THROUGH ITS PROPRIETOR MUHAMMED AMEEN AGED ABOUT 45 YEARS, S/O. KOYAKUTTY, RESIDENT OF MACHINGAL HOUSE, MARADU, MARADU P.O., ERNAKULAM, KERALA-682304. …PETITIONER (BY SRI. GAYATRI S.R., ADVOCATE) AND: 1. UNION OF INDIA THROUGH ITS SECRETARY, GOVERNEMENT OF INDIA, MINISTRY OF FINANCE, DEPARTMENT OF REVENUE, NORTH BLOCK, NEW DELHI-110001. 2. THE GOODS AND SERVICES TAX COUNCIL THROUGH ITS SECRETARY, OFFICE OF THE GST COUNCIL SECRETARIAT, 5TH FLOOR, TOWER II, JEEVAN BHARTI BUILDING, JANPATH ROAD, CONNAUGHT PLACE, NEW DELHI-110001. Digitally signed by SAROJA HANGARAKI Location: High Court of Karnataka, Dharwad Bench, Dharwad - 2 - HC-KAR NC: 2025:KHC-D:12989 WP No. 105123 of 2024 3. COMMISSIONER OF COMMERCIAL TAXES KARNATAKA, VANIJYA THERIGE KARYALAYA, GANDHI NAGAR, KALIDASA ROAD, BENGALURU-560009. 4. JOINT COMMISSIONER OF COMMERCIAL TAXES (APPEALS), BELAGAVI DIVISION, VISVESVARAYA NAGAR, SADASHIV NAGAR, BELAGAVI, KARNATAKA-590019. 5. JOINT COMMISSIONER OF COMMERCIAL TAXES (ENFORCEMENT), BELAGAVI-590001. 6. ASSISTANT COMMISSIONER OF COMMERCIAL TAXES (ENFORCEMENT), VIJAYAPURA, COMMERCIAL TAX DEPARTMENT COMMERCIAL TAX BUILDING, AFZALPUR TAKKE, VIJAYAPURA, KARNATAKA-586102. …RESPONDENTS (BY SRI. M.B. KANAVI, CGSE FOR R1; SRI. GIRISH S. HULAMANI, ADVOCATE FOR R2; SRI. SHARAD V. MAGADUM, AGA FOR R3 TO R6 ) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA, PRAYING TO I. ISSUE A WRIT, ORDER OR DIRECTION IN THE NATURE OF CERTIORARI QUASHING THE IMPUGNED APPELLATE ORDER APPEAL NO. APL/GST-121-2218- 409 (ANNEXURE-A) DATED. 15.09.2022 WHICH HAS BEEN PASSED BY WITHOUT JURISDICTION BY THE RESPONDENT NO.4. II. ISSUE A WRIT, ORDER OR DIRECTION IN THE NATURE OF CERTIORARI QUASHING THE IMPUGNED CONFISCATION ORDER (ANNEXURE-B) DATED. 17.09.2021 WHICH HAS BEEN ISSUED BY WITHOUT JURISDICTION PASSED BY THE RESPONDENT NO.6. III. DIRECT THE RESPONDENTS TO REFUND THE AMOUNT RECEIVED BY THE RESPONDENT THROUGH AUCTION OF THE GOODS.IV. ISSUE ANY OTHER WRIT OR ORDER OR DIRECTION, WHICH THIS HON BLE COURT MAY - 3 - HC-KAR NC: 2025:KHC-D:12989 WP No. 105123 of 2024 DEEM FIT AND PROPER UNDER THE FACTS AND CIRCUMSTANCES OF THE PRESENT CASE.V. GRANT COSTS AND INTEREST AND ETC. THIS PETITION, COMING ON FOR ORDERS THIS DAY, ORDER WAS MADE THERIN AS UNDER:

ORAL ORDER

(PER: THE HON'BLE MR. JUSTICE SURAJ GOVINDARAJ)

1.

The petitioner is before this Court seeking for the following reliefs: i. Issue a writ, order or direction in the nature of certiorari quashing the impugned Appellate Order Appeal No. APL/GST-121-2218-409 (Annexure-A) dated 15.09.2022 which has been passed by without juri iction by the respondent no.4. ii. Issue a writ, order or direction in the nature of certiorari quashing the impugned confiscation order (Annexure-B) dated. 17.09.2021 which has been issued by without juri iction passed by the respondent no.6. iii. Direct the Respondents to refund the amount received by the respondent through auction of the goods.

iv. Issue any other writ or order or direction, which this Hon’ble Court may deem fit and proper under the facts and circumstances of the present case.

v. Grant costs and interest. HC-KAR NC: 2025:KHC-D:12989 vi. Grant such further and other reliefs as the nature and circumstances of the case may require.

2.

A notice was issued to the petitioner calling upon him to pay the differential tax along with penalty. Consequent to the said notice, the goods in question were seized/confiscated and subsequently brought to auction. The proceeds of the said auction are presently lying with the respondents.

3.

Learned counsel for the petitioner submits that the amount realized from the auction is in excess of 20% of the demand raised against the petitioner. In such circumstances, it is submitted that the petitioner has complied with the requirement under Clause (b) of Sub-section (8) of Section 112 of the Karnataka Goods and Services Tax Act, 2017 (hereinafter referred to as ‘the KGST Act’). Accordingly, the petitioner would be entitled to the benefit of Section 112(9) of the KGST HC-KAR NC: 2025:KHC-D:12989 Act, and no further recovery proceedings can be initiated against him pending appeal.

4.

In light of the fact that the GST Appellate Tribunal has not yet become operational, liberty is reserved to the petitioner to approach the Tribunal within 60 days from the date on which the Tribunal becomes functional, in terms of Notification dated 17.09.2025. 5. The respondents shall not initiate or continue any recovery proceedings against the petitioner during this interim period, subject to the auction proceeds continuing to be held in deposit.

6.

The writ petition stands disposed of accordingly. (SURAJ GOVINDARAJ) JUDGE

VB/Ct:pa/List No.: 3 Sl No.: 24

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.