- 1 - HC-KAR NC: 2025:KHC:54581 WP No. 28256 of 2024 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. 28256 OF 2024 (T-RES) BETWEEN: M/S S.R.S TRAVELS AND LOGISTICS PRIVATE LIMITED REGISTERED UNDER COMPANIES ACT OF 1956, NO.321, TSP ROAD, OPPOSITE TO BANGALORE MEDICAL COLLEGE, KALASIPALYAM, BANGALORE-560 092. REPRESENTED BY ITS, MANAGING DIRECTOR SMT.MEGHA BANGALORE RAJASHEKHARA D/O LATE K T RAKASHEKHARA AGED ABOUT 47 YEARS, OFFICE AT NO.321, TSP ROAD, OPPOSITE TO BANGALORE MEDICAL COLLEGE, KALASIPALYAM, BENGALURU-560 002. …PETITIONER (BY SMT. VINITHA.M, ADVOCATE FOR SRI. P.B.HARISH, ADVOCATE) AND: 1. DEPUTY COMMISSIONER OF COMMERCIAL TAXES (AUDIT)-3.1, DGSTO-3, II FLOOR, BMTC BUILDING, SHANTI NAGAR, BANGALORE-560 027. 2. COMMERCIAL TAX OFFICER (ENF-22), SOUTH ZONE, O/O, THE ADDITIONAL COMMISSIONER OF COMMERCIAL TAXES(ENFORCEMENT) SOUTH V T K -2 BUILDING, RAJENDRANAGARA, KORAMANGALA, BENGALURU-560 047. Digitally signed by CHANDANA B M Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:54581 WP No. 28256 of 2024 3. ADDITIONAL DIRECTOR, DGGI BENGALURU ZONAL UNIT NO.112, S.P. ENCLAVE, ADJACENT TO KARNATAKA BANK, K.H.ROAD, BENGALURU – 560 027. …RESPONDENTS (BY SRI. K. HEMAKUMAR, AGA FOR R-1 & R-2 SRI. M.N. KUMAR, ADVOCATE FOR R-3) THIS W.P. IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO CALL FOR THE RECORDS OF THE CASE AND AFTER SCRUTINIZING THE SAME, TO STRIKE DOWN AND QUASH THE IMPUGNED ORDER-IN-ORIGINAL DTD. 31.08.2024 BEARING NO. DCCT/ADJ3.1/2024-25 VIDE ANNX-A PASSED BY THE LD.R-1 AND THE IMPUGNED SHOW CAUSE NOTICE DTD. 29.01.2024 BEARING NO. ADCOM/ENF/SZ/CTO-11/INS-01-/2023-24 VIDE ANNX-B PASSED BY THE LD. R-2. THIS 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: “ i) Issue a Writ of Certiorari or any other Writ or Order or direction appropriate nature to call for the records of the case and after scrutinizing the same, to strike down and quash the impugned Order In-Original dated 31.08.2024 bearing No. DCCT/ADJ3.1/ /2024-25 vide ANNEXURE -A passed by the Ld. Respondent No. 1 an impugned Show Cause Notice dated 29.01.2024 bearing ADCOM/ENF/SZ/CTO-11/INS-01-/2023-24 vide ANNEXURE-B by the Ld. Respondent No.2. - 3 - HC-KAR NC: 2025:KHC:54581 WP No. 28256 of 2024 ii) Pass any other order or orders as this Hon’ble court deems fit and proper in the facts and circumstances of the present case.” 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? (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 - HC-KAR NC: 2025:KHC:54581 WP No. 28256 of 2024 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); 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 - 5 - HC-KAR NC: 2025:KHC:54581 WP No. 28256 of 2024 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 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. - 6 - HC-KAR NC: 2025:KHC:54581 WP No. 28256 of 2024 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 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 notices dated 29.01.2024 and 21.06.2024 at Annexures-B and F - 7 - HC-KAR NC: 2025:KHC:54581 WP No. 28256 of 2024 respectively as well as order dated 31.08.2024 at Annexure-A 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 notices dated 29.01.2024 and 21.06.2024 at Annexures-B and F respectively as well as order dated 31.08.2024 at Annexure-A 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.: 0