- 1 - HC-KAR NC: 2025:KHC:48192 WP No. 24043 of 2025 C/W WP No. 23899 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 21ST DAY OF NOVEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 24043 OF 2025 (T-RES) C/W WRIT PETITION NO. 23899 OF 2025 (T-RES) IN WP No. 24043/2025 BETWEEN: M/S SUMEET TRADING CO A PROPRIETARY CONCERN NO. 706, 7TH CROSS 10TH MAIN ROAD AKASH VIHAR LAYOUT BANGALORE 560 064 (GTIN 29AIZPD6322RIZA) REPRESENTED BY ITS PROPRIETOR MR. SUMEET KUMAR DASH S/O JAGADISH CHANDRA DASH AGED ABOUT 46 YEARS …PETITIONER (BY SRI. RAJEEV CHANNAPPA NULVI, ADVOCATE) AND: THE DEPUTY DIRECTOR OFFICE OF THE ADDITIONAL DIRECTOR GENERAL DIRECTORATE GENERLA OF GST INTELLIGENC E BELAGAVI ZONAL UNIT SHRI LAXMI COMPLEX NO. 4855/83 Digitally signed by SHARADAVANI B Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:48192 WP No. 24043 of 2025 C/W WP No. 23899 of 2025 SADASHIV NAGAR 1ST CROSS APMC ROAD BELAGAVI KARNATAKA 590 019 …RESPONDENT (BY SRI.MADHU N.RAO, ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO ISSUE A WRIT OF ISSUE A WRIT OF CERTIORARI OR A DIRECTION IN THE NATURE OF WRIT OF CERTIORARI QUASHING THE IMPUGNED ORDER VIDE F. NO. DGGI/INV/GST/3641/2024 DATED 18/06/2025 PASSED BY THE RESPONDENT AUTHORITY I.E., THE DEPUTY DIRECTOR, DIRECTORATE GENERAL OF GST INTELLIGENCE, BELAGAVI ZONAL UNIT. (ANNEXURE-B), ETC. IN WP NO. 23899/2025 BETWEEN: M/S SHREEYA STEEL A PARTNERSHIP FIRM REGISTRERED UNDER KARNATAKA PARTNERSHIP ACT 1954 WARD NO. 19/5, KHATHA NO. 2625/3885/2122, K R EXTENSION, MADHUGIRI, TUMKURU DISTRICT, KARNATAKA - 572 132. (GTIN 29AEPFS5695N1ZP) REPRESENTED BY ITS PARTNER MR. SUMEET KUMAR DASH S/O JAGADISH CHANDRA DASH AGED ABOUT 46 YEARS ...PETITIONER (BY SRI. RAJEEV CHANNAPPA NULVI, ADVOCATE) AND: THE DEPUTY DIRECTOR OFFICE OF THE ADDITIONAL DIRECTOR GENERAL, DIRECTORATE GENERAL OF GST INTELLIGENCE, - 3 - HC-KAR NC: 2025:KHC:48192 WP No. 24043 of 2025 C/W WP No. 23899 of 2025 BELAGAVI ZONAL UNIT, SHRI LAXMI COMPLEX, NO. 4855/83, SADASHIV NAGAR, 1ST CROSS, APMC ROAD, BELAGAVI, KARNATAKA 590 019. ...RESPONDENT (BY SRI.MADHU N.RAO, ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO ISSUE A WRIT OF CERTIORARI OR A DIRECTION IN THE NATURE OF WRIT OF CERTIORARI QUASHING THE IMPUGNED ORDER VIDE F.NO. DGGI/INV/GST/ 3642/2024 DATED 18/06/2025 PASSED BY THE RESPONDENT AUTHORITY I.E., THE DEPUTY DIRECTOR, DIRECTORATE GENERAL OF GST INTELLIGENCE, BELAGAVI ZONAL UNIT (ANNEXURE-B), ETC. THESE PETITIONS, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR ORAL COMMON ORDER In these petitions, petitioner seeks the followign prayers: IN W.P.NO.24043/2025: "WHEREFORE, it is humbly prayed that this Hon'ble Court may be pleased to:- A. Issue a Writ of issue a Writ of Certiorari or a direction in the nature of Writ of Certiorari quashing the impugned Order vide F. No. - 4 - HC-KAR NC: 2025:KHC:48192 WP No. 24043 of 2025 C/W WP No. 23899 of 2025 DGGI/INV/GST/3641/2024 dated 18/06/2025 passed by Respondent authority i.e., The DEPUTY DIRECTOR, Directorate General of GST Intelligence, Belagavi Zonal Unit. (ANNEXURE-'B'); the B. Issue a Writ of issue a Writ of Certiorari or a direction in the nature of Writ of Certiorari declaring Rule 86A of the KGST/CGST Rules, 2017 as Ultra Vires, as being unreasonable, arbitrary, besides being discriminatory and violative of Article 19(1)(g) and 300A of the Constitution of India. C. To pass any such other Writ, Order or Direction as this Hon'ble court might deem fit to be issued in the fact and circumstances of the case in the interest of justice and equity; D. To direct the Respondents to pay the costs of this Writ Petition as this Hon'ble Court deems fit." IN W.P.NO.23899/2025: "WHEREFORE, it is humbly prayed that this Hon'ble Court may be pleased to:- A. Issue a Writ of issue a Writ of Certiorari or a direction in the nature of Writ of Certiorari quashing the impugned Order vide F. No. DGGI/INV/GST/3642/2024 dated 18/06/2025 passed by Respondent authority i.e., The DEPUTY DIRECTOR, Directorate General of GST Intelligence, Belagavi Zonal Unit. (ANNEXURE-'B'); the B. Issue a Writ of issue a Writ of Certiorari or a direction in the nature of Writ of Certiorari declaring Rule 86A of the KGST/CGST Rules, 2017 as Ultra Vires, as being unreasonable, arbitrary, besides being discriminatory and violative of Article 19(1)(g) and 300A of the Constitution of India. - 5 - HC-KAR NC: 2025:KHC:48192 WP No. 24043 of 2025 C/W WP No. 23899 of 2025 C. To pass any such other Writ, Order or Direction as this Hon'ble court might deem fit to be issued in the fact and circumstances of the case in the interest of justice and equity; D. To direct the Respondents to pay the costs of this Writ Petition as this Hon'ble Court deems fit." 2. After arguing the matters for some time, learned counsel for the petitioner submits that the petitioner would appear before the respondent on 01.12.2025 and submit his reply along with documents to the impugned communications/orders and orders at Annexure-B dated 18.06.2025 and the respondents may be directed to consider the reply and documents to be submitted by the petitioner and provide an opportunity and hear the petitioner and proceed further in accordance with law. 3. The said submission is placed on record. 4. Accordingly, Petitions are disposed of directing the petitioner to appear before the respondent on 01.12.2025. - 6 - HC-KAR NC: 2025:KHC:48192 WP No. 24043 of 2025 C/W WP No. 23899 of 2025 5. If the petitioner appears before the respondent on 01.12.2025 and file objections along with documents, the first respondent shall consider the same and provide sufficient and reasonable opportunity to the petitioner and here him and pass appropriate orders within a period of 15 days from 01.12.2025. Subject to the aforesaid directions, these petitions stand disposed of. Sd/- (S.R.KRISHNA KUMAR) JUDGE BSV/List No.: 2 Sl No.: 28