M/S The Pavilion Owners Association vs. The Commissioner Of Commercial Taxes

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WP/15856/2025HC KarnatakaGSTCNR KAHC01034612202502 July 2025Bench: SURAJ GOVINDARAJ5 pages
For Petitioner: SRI. GOWRISHANKAR PRASAD H R., ADVOCATEFor Respondent: SMT. JYOTHI.M.MARADI, HCGP

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Cause title — parties, addresses and appearances
- 1 - HC-KAR NC: 2025:KHC:23768 WP No. 15856 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 2ND DAY OF JULY, 2025 BEFORE THE HON'BLE MR. JUSTICE SURAJ GOVINDARAJ WRIT PETITION NO. 15856 OF 2025 (T-RES) BETWEEN: M/S THE PAVILION OWNERS ASSOCIATION NO. 175 AND 176, BEGUR ROAD, BILEKAHALLI, BANNERGHATTA ROAD, BENGALURU - 560 076 REPRESENTED BY ONE OF ITS SECRETARY SRI. SUJAY KRISHNA, RESIDING AT NO. 405, BALAJI ELITE APARTMENT, 24TH MAIN, 2ND SECTOR, HSR LAYOUT, BENGALURU – 560 102 …PETITIONER (BY SRI. GOWRISHANKAR PRASAD H R.,ADVOCATE) AND: 1. THE COMMISSIONER OF COMMERCIAL TAXES VANIJYA TERIGE KARYALAYA, GANDHINAGAR, BENGALURU – 560 009. 2. THE ASSISTANT COMMISSIONER OF COMMERCIAL TAXES, (ENFORCEMENT-17, SOUTH ZONE, RAJENDRANAGARA, KORAMANGALA,BENGALURU-560047. 3. THE DEPUTY COMMISSIONER OF COMMERCIAL TAXES, (AUDIT-4.3, 6TH FLOOR, ROOM NO. 603, BMTC BUILDING, 80 FEET ROAD, KORAMANGALA, BENGALURU - 560 047 Digitally signed by SHWETHA RAGHAVENDRA Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2025:KHC:23768 WP No. 15856 of 2025 4. THE JOINT COMMISSIONER OF COMMERCIAL TAXES APPEALS-4, BMTC BUILDING, 80 FEET ROAD, KORAMANGALA, BENGALURU - 560 047. …RESPONDENTS (BY SMT. JYOTHI.M.MARADI, HCGP) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASHING THE FOLLOWING IMPUGNED ORDERS PASSED BY THE DEPUTY COMMISSIONER OF COMMERCIAL TAXES, AUDIT-4.3, DGSTO- 4, BENGALURU, THE 3RD RESPONDENT UNDER SEC. 73 OF THE GST ACT,I) ORDER BEARING NO. DCCT(AUDIT)4.3/GST- ADJ/2024-25 DATED 06-08-2024 AND CONSEQUENTIAL SUMMARY ORDER IN FORM GST DRC-07 BEARING REFERENCE NO. ZD2908240391860 DTD. 09-08-2024 (ANNEXURES - F1 AND F2) FOR THE FY 2019-2020). THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE SURAJ GOVINDARAJ

ORAL ORDER

1.

Learned AGA accepts notice for respondents.

2.

The petitioner is before this Court seeking for the following reliefs: a) “To issue a WRIT of CERTIORARI, MANDAMUS or any other writ or direction in the nature of a writ quashing the following impugned orders passed by the Deputy Commissioner of Commercial Taxes, Audit-4.3, DGSTO-4, Bengaluru, the 3rd Respondent under Sec. 73 of the GST Act, HC-KAR NC: 2025:KHC:23768 i) Order bearing No. DCCT(Audit)4.3/GST- ADJ/2024-25 dated 06- 08-2024 and consequential summary order in Form GST DRC - 07 bearing reference No. ZD2908240391860 dtd. 09-08-2024 (ANNEXURES - 'F-1', & 'F-2') for the FY 2019-20; ii) Order bearing No. DCCT(Audit)4.3/GST- ADJ/2024-25 dated 5- 10-2024 and consequential summary order in Form GST DRC -07 bearing reference No. ZD2910240099766 dtd. 05-10- 2024 (ANNEXURES - 'G -1', & 'G-2') for the FY 2020-21; iii) Order bearing No. DCCT(Audit)4.3/GST- ADJ/2024-25 dated 05-10-2024 and consequential summary order in Form GST DRC - 07 bearing reference No. ZD2910240100070 dtd. 05-10-2024 (ANNEXURES - 'H -1', & 'H-2') for the FY 2021-22; iv) Order bearing No. DCCT(Audit)4.3/GST- ADJ/2024-25 dated 05- 10-2024 and consequential summary order in Form GST DRC - 07 bearing reference No. ZD291024010040A dtd. 05-10-2024 (ANNEXURES - ' J-1', & 'J-2') for the FY 2022-23; v) Order bearing No. DCCT(Audit)4.3/GST- ADJ/2024-25 dated 05- 10-2024 and consequential summary order in Form GST DRC - 07 bearing reference No. ZD291024010077T dtd. 05-10-2024 (ANNEXURES - 'K -1', & 'K-2') for the FY 2023-24; or b) Alternatively, issue Writ of Mandamus directing the Joint Commissioner of Commercial Taxes, (Appeals)-4, Bengaluru to entertain the appeals under Sec. 107 of the GST Act, which would be filed challenging the above said impugned orders (ANNEXURES F- 1 & 2, G- 1 & 2, H-1 & 2, J-1 & 2, & K-1 & 2, passed by the Deputy Commissioner of Commercial Taxes, Audit-4.3, DGSTO-4, without pressing upon the time line provided under Sec. 107 of the Act and " thereby to dispose the said appeals on merit;

c) To pass any such other Writ, Order or Direction as this Hon'ble court might deem fit to be issued in the HC-KAR NC: 2025:KHC:23768 fact and circumstances of the case, in the interest of justice and equity.”

3.

Learned counsel for the petitioner submits that the lis in the above matter is covered by the Judgment of the Coordinate Bench of this Court passed in M/s. Eternity Projects -v- The Deputy Commissioner of Commercial taxes (Audit)-3.2 and others1 and submits that the impugned order has been passed without issuing a notice and or providing an opportunity of hearing to the petitioner.

4.

In that view of the matter, I pass the following: ORDER i. The impugned orders and consequential summary orders at Annexure-F1 & F2, G1 & G2, H1 & H2, J1 & J2 and K1 & K2, are set aside. ii. The GST registration of the petitioner shall stand restored. iii. The matter is relegated to the status of show cause notice issued to the petitioner and the 1 WP No.30307/2024 DD 19.11.2024 HC-KAR NC: 2025:KHC:23768 petitioner is directed to appear before respondent No.2 on 29.07.2025 at 2.30 p.m. without further notice. iv. Petitioner shall pay a cost of Rs.25,000/- (Rupees Twenty give thousand only) to the Karnataka State Legal Services Authority, within a period of two weeks from today. v. With the above observations, the petition stands disposed of. (SURAJ GOVINDARAJ) JUDGE

KTY List No.: 1 Sl No.: 34

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.