- 1 - HC-KAR NC: 2025:KHC:54659 WP No. 13025 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 19TH DAY OF DECEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 13025 OF 2025 (T-RES) BETWEEN: M/S MILLION LIGHTS REPRESENTED HEREIN BY ITS PROPRIETOR, SHRI RAMESH CHAND, AGED ABOUT 69 YEARS, S/O H. JAWAHARLAL, HAVING ADDRESS AT NO.32/1, 2ND AND 4TH FLOOR, 5TH CROSS, SIDDAIAH ROAD, WILSON GARDEN, BENGALURU – 560 027 …PETITIONER (BY SRI. BHARAT RAICHANDANI, SRI. RAAGHUL PIRAANESH AND SRI. CHANDRA KIRAN K., ADVOCATES) AND: 1. UNION OF INDIA REPRESENTED HEREIN BY SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI – 110 001 2. THE ADDITIONAL DIRECTOR GENERAL, O.O, THE PRINCIPAL ADDITIONAL DIRECTOR GENERAL, NO.112, S.P. ENCLAVE, ADJACENT TO KARNATKA BANK, K.H. ROAD, BENGALURU – 560 0027 3. THE SENIOR INTELLIGNECE OFFICER, DGGI, BZU BENGALURU, NO.112, S.P. ENCLAVE, ADJACENT TO KARNATKA BANK, K.H. ROAD, BENGALURU – 560 0027 Digitally signed by CHANDANA B M Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:54659 WP No. 13025 of 2025 4. THE ADDITIONAL COMMISSIONER OF CENTRAL TAX, BANGALORE SOUTH COMMISSIONERATE, CENTRAL REVENUE BUILDING, ANNEX BUILDING, QUEEN’S ROAD, BENGALURU – 560 001. 5. THE JOINT COMMISSIONER OF CENTRAL TAX, BANGALORE SOUTH COMMISSIONERATE, CENTRAL REVENUE BUILDING, ANNEX BUILDING, QUEEN’S ROAD, BENGALURU – 560 001 …RESPONDENTS (BY SRI. AKASH B. SHETTY, ADVOCATE FOR R1 & R2) THIS W.P. IS FILED UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ISSUE A WRIT OF CERTIORARI, OR A WRIT OR ORDER OR DIRECTION IN THE NATURE OF WRIT OF CERTIORARI AND SET ASIDE THE IMPUGNED NOTICE VIDE SCN NO. 111/2024-25 DGGI BZU AND DIN 202503DSS00000555CBF DATED 13.03.2025 (ANNEXURE A) AND ETC., THIS PETITION, COMING ON FOR PRELIMINARY HEARING IN ‘B’ GROUP, 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: a) Issue a writ of certiorari, or a writ or order or direction in the nature of writ of certiorari and set aside the Impugned Notice vide SCN No. 111/2024-25 DGGI BZU and DIN 202503DSS00000555CBF dated 13.03.2025 (Annexure A) issued by the Respondent No. 2 as bad in law. - 3 - HC-KAR NC: 2025:KHC:54659 WP No. 13025 of 2025 b) Issue a writ of Mandamus, or a writ or order or direction in the nature of writ of mandamus and direct the Respondent No. 2 to 5 to not to proceed further with the Impugned Notice. c) Issue any other direction or grant any other relief, as deemed fit in the facts and circumstances of this case, in the interest of justice. d) Issue a direction to provide for the cost of this petition. 2. Though several contentions have been urged by both sides in support of their respective claims, the issue in controversy between the parties is directly and squarely covered by the judgment of this Court in the case of M/S Pramur Homes And Shelters Vs. The Union of India and Ors. in WP No.33081/2025 dated 11.12.2025. 3. In the said judgment, this Court formulated two points for consideration, which reads as under: (i) Whether clubbing/consolidation/bunching/ combining of multiple tax periods/financial years in a Single/Composite Show cause notice issued under Section 73 / 74 of the CGST/ KGST Act , 2017 is permissible and valid in law? - 4 - HC-KAR NC: 2025:KHC:54659 WP No. 13025 of 2025 (ii) Whether the impugned Show cause notice dated 30.09.2025 issued by the 4th respondent to the petitioner for the tax periods/financial years from 2019-20 to 2023-24 under Section 74 of the CGST/ KGST Act, 2017 warrants interference by this Court in the present petition? 4. Issue No.1 was answered by this Court in favour of the petitioner by holding as under: Point No.(i) is accordingly answered in favour of the petitioner/tax payer/assessee by holding that clubbing/ consolidation/ bunching/ combining of multiple tax periods/financial years in a Solitary/Single/Composite Show cause notice issued under Section 73/74 of the CGST/KGST Act is illegal, invalid, impermissible and without jurisdiction or authority of law and contrary to the provisions of the CGST/KGST Act. 5. So also point No.2 was also answered by this Court in favour of the petitioner by quashing the impugned Show Cause Notice by holding as under: “Re: Point No.(ii); - 5 - HC-KAR NC: 2025:KHC:54659 WP No. 13025 of 2025 9. While dealing with Point No. (i) supra, I have already come to the conclusion that clubbing / consolidation / bunching/ combining of multiple tax periods/financial years in a Solitary/Single/Composite Show cause notice issued under Section 73 / 74 of the CGST / KGST Act is illegal, invalid, impermissible and without jurisdiction or authority of law and contrary to the provisions of the CGST / KGST Act. In the instant case, a perusal of the impugned Show cause notice dated 30.09.2025 will indicate that the same encompasses and pertains to multiple tax periods/financial years, viz., from 2019-20 to 2023-24, which is impermissible in law and consequently, the impugned Show cause notice and all further proceedings pursuant thereto are also vitiated and deserve to be quashed reserving liberty to the respondents to initiate any action/proceedings in accordance with law. Point No.(ii) is also accordingly answered in favour of the petitioner/tax payer/assessee by holding that the impugned Show cause notice dated 30.09.2025 issued by the 4th respondent to the petitioner for the tax periods/financial years from 2019- 20 to 2023-24 under Section 74 of the CGST/KGST Act is illegal, invalid, impermissible, arbitrary and without jurisdiction or authority of law and contrary to - 6 - HC-KAR NC: 2025:KHC:54659 WP No. 13025 of 2025 the provisions of the CGST/KGST Act and the impugned show cause notice and all further proceedings, orders, notices pursuant thereto deserve to be quashed by reserving liberty in favour of the respondents to initiate proceedings in accordance with law. 10. In the result, I pass the following: ORDER (i) Petition is hereby allowed. (ii) The impugned show-cause notice at Annexure-A dated 30.09.2025 issued by respondent No.4 and all further proceedings, orders, notices etc., pursuant thereto initiated/to be initiated by the respondents are hereby quashed. (iii) The respondents are however reserved liberty to initiate appropriate proceedings in accordance with law and if such proceedings are initiated by the respondents, petitioner would be entitled to contest / defend the same in accordance with law.” 6. The issue in controversy involved in the present petition also relates to clubbing/consolidation/bunching/combining of multiple tax periods/financial years/block periods in a - 7 - HC-KAR NC: 2025:KHC:54659 WP No. 13025 of 2025 Single/Composite Show cause notice, which has already been held to be invalid and illegal by this Court in M/S Pramur Homes And Shelters’s case referred to Supra. 7. Under these circumstances, the impugned show cause notice dated 13.03.2025 at Annexure-A passed by respondent No.2 deserve to be quashed. 8. In the result, I pass the following: ORDER (i) Petition is hereby allowed and disposed of in terms of M/S Pramur Homes And Shelters Vs. The Union of India and Ors. in WP No.33081/2025 dated 11.12.2025. (ii) The impugned show cause notice dated 13.03.2025 at Annexure-A passed by respondent No.2 and all further proceedings, orders, notices etc., pursuant thereto initiated/to be initiated by the respondents are hereby quashed. (iii) The respondents are however reserved liberty to initiate appropriate proceedings in accordance with law and if such proceedings are initiated by the respondents, petitioner would be entitled to contest / defend the same in accordance with law. Sd/- (S.R.KRISHNA KUMAR) JUDGE BMC List No.: 2 Sl No.: 24