BharatTaxGST

The Additional Commissioner Of Central Tax vs. Educational Testing Services

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WA/784/2026HC KarnatakaGSTCNR KAHC01016225202624 April 2026Bench: S.G.PANDIT,K. V. ARAVIND4 pages
For Respondent: SRI. P B HARISH, ADV

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Heard together (2 matters)

WA No. 784 of 2026
WP NO.23182/2025

Read from the judgment's own cause title. This page is filed under one of them.

Cause title — parties, addresses and appearances
- 1 - HC-KAR NC: 2026:KHC:24630-DB WA No. 784 of 2026 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 24TH DAY OF APRIL, 2026 PRESENT THE HON'BLE MR. JUSTICE S.G.PANDIT AND THE HON'BLE MR. JUSTICE K. V. ARAVIND WRIT APPEAL NO. 784 OF 2026 (T-RES) BETWEEN: 1. THE ADDITIONAL COMMISSIONER OF CENTRAL TAX WEST OIDAR SERVICES DIVISION, BENGALURU WEST COMMISSIONERATE, 1ST FLOOR, TTMC, BMTC BUILDING, KANAKPURA ROAD, BENGALURU URBAN, BENGALURU, KARNATAKA-560 070. 2. THE ADDITIONAL DIRECTOR, DIRECTORATE GENERAL OF GOODS AND SERVICE TAX INTELLIGENCE, MUMBAI ZONAL UNIT 1ST AND 3RD FLOOR, N.T.C. HOUSE, 15, N.M ROAD, BALLARD ESTATE, MUMBAI, MAHARASHTRA-400 001. …APPELLANTS (BY SRI. ARAVIND V CHAVAN, ADV.) AND: EDUCATIONAL TESTING SERVICES (COMPANY INCORPORATED UNDER LAWS OF THE UNITED STATES OF AMERICA) HAVING REGISTERED OFFICE AT 660, ROSEDALE ROAD, PRINCETON, NEW JERSEY 08541, UNITED STATES OF AMERICA. REP. BY ITS AUTHORISED SIGNATORY, VINITHA M Digitally signed by NANJUNDACHARI Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2026:KHC:24630-DB WA No. 784 of 2026 D/O, R.MURALIDHARAN AGED ABOUT 36 YEARS, R/AT B6, 184, BDA FLATS KALLAHALLI, BANGALRE-560042. …RESPONDENT (BY SRI. P B HARISH, ADV.) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT PRAYING TO A) SET ASIDE THE ORDER PASSED BY THE LEARNED SINGLE JUDGE IN WP NO.23182/2025 DATED 17/12/2025 AND B) PASS SUCH OTHER SUITABLE ORDERS. THIS APPEAL, COMING ON FOR PRELIMINARY HEARING, THIS DAY, JUDGMENT WAS DELIVERED THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE S.G.PANDIT AND HON'BLE MR. JUSTICE K. V. ARAVIND

ORAL JUDGMENT

(PER: HON'BLE MR. JUSTICE S.G.PANDIT)

This Writ Appeal by the Revenue under Section 4 of the Karnataka High Court Act is directed against the learned Single Judge’s order dated 17.12.2025 in W.P.No.23182/2025 where under the respondent’s writ petition is allowed quashing the common show cause notice issued under Section 74 of the CGST Act dated 25.06.2025. 2. This Court by order dated 24.04.2026 in W.A.No.1751/2024 and Connected Appeals, allowed HC-KAR NC: 2026:KHC:24630-DB the Writ Appeals and restored the show cause notice and Orders in Original. The decision rendered therein would aptly apply to these appeals also. Since we have held that the consolidated/common show cause notice is permissible, we deem it appropriate to provide liberty to the respondent to file reply to the show cause notice impugned in the Writ Petition dated 25.06.2025. If the reply is filed within 4 weeks’ the proper officer shall consider the same on merits.

3.

Hence, the following:

ORDER (i) Writ Appeal is allowed.

(ii) The order of the learned single judge dated 17.12.2025 in W.P.No.23182/2025 is set aside.

(iii) The show cause notice dated 25.06.2025 is restored. HC-KAR NC: 2026:KHC:24630-DB (iv) The respondent is provided four weeks’ time from the day this Order is uploaded on the website of this Court to file reply to the show cause notice dated 25.06.2025. The proper officer shall consider the reply filed, if any, on merits.

(v) Costs made easy. (S.G.PANDIT) JUDGE (K. V. ARAVIND) JUDGE

MPK CT:bms List No.: 2 Sl No.: 0

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