- 1 - HC-KAR NC: 2025:KHC:54647 WP No. 36930 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 17TH DAY OF DECEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO.36930 OF 2025 (T-RES) BETWEEN: M/S SREE GOWRI GANESHA CHITS PVT LTD HAVING ITS OFFICE AT NO. 307, 1ST FLOOR, 2ND MAIN, 7TH CROSS, DOMLUR LAYOUT, BANGALORE - 560 071. A PRIVATE LIMITED COMPANY REPRESENTED BY ITS CHAIRMAN AND MANAGING DIRECTOR- MR. M LOKESH REDDY S/O N. MUNIYAPPA AGED ABOUT 59 YEARS NO.307, 1ST FLOOR, 2ND MAIN 7TH CROSS, DOMLUR LAYOUT BENGALURU – 560 071. …PETITIONER (BY SMT. LAKSHMI MENON, ADVOCATE) AND: 1. ASSISTANT COMMISSIONER OF CENTRAL TAX GST EAST COMMISSIONERATE BENGALURU, EAST DIVISION-1, 6TH FLOOR, B WING, TRAFFIC AND TRANSIT MANAGEMENT CENTRE, BMTC BUS STAND, OLD AIRPORT ROAD, BANGALORE-560 071. 2. DEPUTY COMMISSIONER OF CENTRAL TAX, ANTI EVASTION, OFFICER OF THE PRL.COMISSIONER OF CENTRAL TAX, GST COMMISIONARATE, BENGALURU EAST, TRAFFIC AND TRANSIT MANAGEMENT CENTRE, BMTC BUS STAND, OLD AIRPORT ROAD, Digitally signed by CHANDANA B M Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:54647 WP No. 36930 of 2025 DOMMALURU, BANGALORE-560 071. …RESPONDENTS (BY SRI. JEEVAN.J.NEERALGI, ADVOCATE) THIS W.P IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUION OF INDIA PRAYING TO SET ASIDE THE ORDER IN ORIGINAL BEARING NO. 72/2024-25 AND DIN NO 2024095700000883E55 WITH DATE OF PASSING AS 2.09.2024 AND DATE OF ISSUE 3.09.2024 ISSUED BY THE R-1 ANNX-A. THIS PETITION, COMING ON FOR PRELIMINARY HEARING, 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: “ i) Issue a writ of Certiorari quashing the show cause notice under section. 74(1) of the Act dated 23.03.2022 vide SCN Ref No: 30/2021-22/DC/AE/GST bearing DIN No. 2022035700000000CA90 issued by the Respondent No.2 and referred as Annexure-A1. ii) Issue a writ of Certiorari quashing the Order-in- Original No. 72/2024-25 bearing DIN No: 20240957000000883E55 date of issue 03.09.2024 passed by Respondent No. 1 and referred as Annexure-A2. iii) Alternatively, remand the matter to the Show Cause Notice Stag directing the Respondent No.1 to adjudicate the proceedings afresh accordance with law, after granting the Petitioner a fair and effective opportunity - 3 - HC-KAR NC: 2025:KHC:54647 WP No. 36930 of 2025 to be heard and considering all documents and records furnished; iv) And pass such other orders as this Hon'ble Court deems fit and in the interest of justice and equity.” 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/ - 4 - HC-KAR NC: 2025:KHC:54647 WP No. 36930 of 2025 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); 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 - 5 - HC-KAR NC: 2025:KHC:54647 WP No. 36930 of 2025 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 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 - 6 - HC-KAR NC: 2025:KHC:54647 WP No. 36930 of 2025 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 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 - HC-KAR NC: 2025:KHC:54647 WP No. 36930 of 2025 7. Under these circumstances, the impugned show cause notice dated 23.03.2022 at Annexure-A1 as well as order dated 03.09.2024 at Annexure-A2 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 23.03.2022 at Annexure-A1 as well as order dated 03.09.2024 at Annexure-A2 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 SV List No.: 4 Sl No.: 2