- 1 - HC-KAR NC: 2025:KHC:42328 WP No. 18142 of 2021 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 23RD DAY OF OCTOBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 18142 OF 2021 (T-RES) BETWEEN: HALAGAPPA ARECANUT TRADERS 2KM HASUDI ROAD, NEAR PURLE, HOLEBENAVALLI POST, VIA NIDIGE, SHIVAMOGGA- 577 222. REPRESENTED BY ITS PARTNER SHRI H MARIYAPPA, S/O N R HALAGAPPA, AGED ABOUT 68 YEARS, …PETITIONER (BY SRI. B.G.CHIDANAND URS FOR SRI. BOLLAJU VENUGOPAL., ADVOCATE) AND: THE ADDITIONAL COMMISSIONER OF CENTRAL TAX, OFFICE OF THE PRINCIPAL COMMISSIONER OF CENTRAL TAX, GST COMMISSIONERATE, VINAYA MARGA SIDDHARTHANAGAR, MYSORE- 570 011. …RESPONDENT (BY SRI. JEEVAN NEERALGI., ADVOCATE) THIS WP FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO-QUASH THE SHOW CAUSE NOTICE DATED 17.08.2021 ENCLOSED AS ANNEXURE-E HOLD THAT THE PETITIONER IS TO TAKE ITC OF GST PAID BY THEM ON RCM BASISAWARD COST OF THIS PETITION. Digitally signed by SHARADAVANI B Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2025:KHC:42328 WP No. 18142 of 2021 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 Learned counsel for the petitioner invited my attention to the C.B.I & C Circular No. 171/03/2022-GST, dated 06.07.2022 in order to contend that in view of the said Circular, impugned show cause notice deserves to be quashed. It is also submitted that the petitioner has reversed the input tax credit leading to the situation of revenue neutrality and on this ground also the impugned notice deserves to be quashed. 2. Per contra, learned counsel for the respondent submits that if the petitioner submits a reply to the show cause notice, the respondents would consider the same and further proceed in accordance with law. 3. In view of the aforesaid facts and circumstances, I deem it just and appropriate to dispose of this petition directing the petitioner to submit a reply to - 3 - HC-KAR NC: 2025:KHC:42328 WP No. 18142 of 2021 the impugned show cause notice at Annexure - E dated 17.08.2021 bearing DIN 20210857YY0000272003 in Form GST DRC-01 (in C.No.GEXCOM/ADJN/GST/ADC/58/2021- ADJN) within a period of six weeks from today. 4. If the petitioner submits such a reply within a period of six weeks from today along with reply, documents etc., if any, the respondents shall consider the same and provide sufficient and reasonable opportunity to the petitioner and proceed further in accordance with law bearing in mind the Board Circular dated 06.07.2022 and relevant statutory persuasions. Ordered accordingly and petition stands disposed of. Sd/- (S.R.KRISHNA KUMAR) JUDGE BSV/List No.: 2 Sl No.: 26