M/S K M C Constructions LTD vs. State Of Karnataka

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WP/24600/2023HC KarnatakaGSTCNR KAHC01056674202316 April 2025Bench: S.R.KRISHNA KUMAR5 pages
For Petitioner: SMT. VANI H., ADVOCATEFor Respondent: SMT. JYOTI M. MARADI, HCGP FOR R1 TO R3 SRI. AJAY PRABHU .M., ADVOCATE FOR R4 SRI. AJAY KUMAR .M, ADVOCATE FOR R2

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Cause title — parties, addresses and appearances
- 1 - NC: 2025:KHC:15707 WP No. 24600 of 2023 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 16TH DAY OF APRIL, 2025 BEFORE THE HON'BLE MR JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 24600 OF 2023 (T-RES) BETWEEN: M/S. K.M.C. CONSTRUCTIONS LTD., A COMPANY REGISTERED UNDER THE COMPANIES ACT HAVING ITS BRANCH OFFICE AT NO. 3427 3RD CROSS, 10TH MAIN, INDIRANAGAR BANGALORE - 560 038 REPRESENTED BY ITS AUTHORISED SIGNATORY SRI. T. GOPALAKRISHNA S/O SRI RANGAPPA THIMMAIAH AGED ABOUT 69 YEARS. …PETITIONER (BY SMT. VANI H., ADVOCATE) AND: 1. STATE OF KARNATAKA DEPARTMENT OF FINANCE REPRESENTED BY ITS SECRETARY VIDHANA SOUDHA, AMBEDKAR VEEDHI BANGALORE - 560 001 2. THE BANGALORE DEVELOPMENT AUTHORITY BY ITS CHAIRMAN T CHOWDAIAH ROAD KUMARAPARK WEST BANGALORE - 560 020 3. COMMISSIONER OF COMMERCIAL TAXES VANIJYA THERIGE KARYALAYA - 1 I MAIN ROAD, GANDHINAGAR BANGALORE - 560 009. 4. UNION OF INDIA MINISTRY OF FINANCE REPRESENTED BY ITS SECRETARY Digitally signed by NANDINI B G Location: High Court of Karnataka - 2 - NC: 2025:KHC:15707 WP No. 24600 of 2023 NORTH BLOCK NEW DELHI 110 001 …RESPONDENTS (BY SMT. JYOTI M. MARADI, HCGP FOR R1 TO R3 SRI. AJAY PRABHU .M., ADVOCATE FOR R4 SRI. AJAY KUMAR .M, ADVOCATE FOR R2) THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO DECLARE THAT THE PROVISIONS OF GST ACT AS INAPPLICABLE IN RESPECT OF WORKS CONTRACT WHERE PROVISIONS OF SERVICE ARE MADE PRIOR TO 01/07/2017 IN SO FAR AS PETITIONER IS CONCERNED AND CONSEQUENTLY THAT THE THIRD RESPONDENT OR ANY OTHER AUTHORITY UNDER THEIR JURISDICTION HAVE NO JURISDICTION TO EITHER ISSUE NOTICE OR TO TAKE ANY COERCIVE STEPS AGAINST THE PETITIONER UNDER THE PROVISIONS OF THE GST ACT WITH EFFECT FROM 01/07/2017 AND ETC., THIS WRIT PETITION, COMING ON FOR ORDERS, 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:

"WHEREFORE, the petitioner respectfully prays that Hon'ble Court be pleased to: a. Declare that the provisions of GST Act as inapplicable in respect of works contract where 'provisions of service are made prior to 01.07.2017 in so far as petitioner is concerned and consequently that the third respondent or any other authority under their juri iction have no juri iction to either issue notice or to take any NC: 2025:KHC:15707 coercive steps against the Petitioner under the provisions of the GST Act with effect from 01.07.2017. b. Declare that, GST being an Indirect tax is based on the concept of collect and pay, and the liability to pay is on the taxable person after collecting it from recipient of goods or services Le from the employer of works contract (Respondent No. 2); AND hence direct Respondent 1 being the State Government to direct the Second Respondent to pay /reimburse the differential tax amounts to Petitioner who has already paid GST without collecting it from the second Respondent 2. c. Issue a Writ of Certiorari or a writ in the nature of certiorari to set aside the Endorsement bearing No. BDA/FM/COMP/GST/74/2022-23 dated 18.4.2023 issued by the second respondent vide ANNEXURE H. d. Issue of a Writ of Mandamus or a writ in the nature of Mandamus to direct the Second Respondent to execute a supplementary agreement or any other order providing for payment/reimbursement of differential GST amounts at the rate of 7.6% of the contract value in respect of the works executed or to be executed after 1.7.2017. e. Issue of a Writ of Mandamus or a writ in the nature of Mandamus to direct the Second and the fourth Respondent to refund a sum of Rs. 34,03,391/- deducted as VAT while releasing the amounts due in terms of RA bill Nos. 38 to 53 as per representation reference No. NC: 2025:KHC:15707 KMC/BRO/BDA/EE (NPKL)/P-1/2.9.1.10/2019- 20/11 dated 18.5.2019 vide ANNEXURE F and; f. Pass such other orders as may be deemed appropriate under the circumstances of the case, in the ends of justice."

2.

Heard learned counsel for the petitioner, learned HCGP for respondent Nos.1 and 3, learned counsel for respondent No.2 and learned CGC for respondent No.4 and perused the material on record.

3.

A perusal of the material on record would indicate that insofar as prayer - (a), (b),(c) and (d) (supra) are concerned, the dated 29.08.2023 and in the case of M/s Apoorva Construction NC: 2025:KHC:15707

4.

Insofar as prayer (e) (supra) is concerned, request of the petitioner to direct respondent No.2 - BDA to consider the refund of sum of Rs.34,03,391/-, is to be considered by respondent No.2 - BDA within the stipulated time frame, in accordance with law.

5.

In the result, pass the following: ORDER (i) The petition is hereby disposed off in terms of the judgments - Chandrashekaraiah and Others Vs State of Karnataka and Others; M G Arun Kumar Vs State of Karnataka and M/s Apoorva Construction Co., Vs State of Karnataka and Others. (ii) Respondent No.2 - BDA is directed to consider the request of the petitioner to refund sum of Rs.34,03,391/- deducted as VAT in terms of prayer (e), within a period of six weeks from the date of receipt of copy of this order. (S.R.KRISHNA KUMAR) JUDGE

*bgn/- CT:VS List No.: 1 Sl No.: 31

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.