- 1 - HC-KAR NC: 2026:KHC:17974 WP No. 6583 of 2026 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 2ND DAY OF APRIL, 2026 BEFORE THE HON'BLE MR. JUSTICE S SUNIL DUTT YADAV WRIT PETITION NO. 6583 OF 2026 (T-RES) BETWEEN: M/S. RELIFLEX EXIM SERVICES (OPC) PVT. LTD., (COMPANY INCORPORATED UNDER THE COMPANIES ACT, 2013), NO.78, SY.NO.120/2, DUO TOWN MANSON, ANJANPURA, 80 FEET ROAD, GUNDAPPA LAYOUT, GOTTIGERE, BENGALURU - 560 083, REPRESENTED BY ITS DIRECTOR SRI. ADNAN SHABBIR BOXWALA. …PETITIONER (BY SRI. SWAMY M.M., ADVOCATE) AND: ASSISTANT COMMISSIONER OF COMMERCIAL TAXES LGSTO -027, DGSTO-4, TTMC BUILDING, 80 FEET ROAD, KORAMANGALA, BENGALURU - 560 083. …RESPONDENT (BY SRI. K. HEMA KUMAR, AGA) THIS W.P. IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE IMPUGNED ADJUDICATION ORDER DATED 29.04.2024 BEARING NO.ACCT/LGSTO-27/2AVS3B/2023-24 PASSED BY THE RESPONDENT UNDER SECTION 73 OF KGST/CGST ACT FOR THE F. Y. APRIL, 2018 - MARCH, 2019 VIDE ANNEXURE - A AND ETC., Digitally signed by VIJAYA P Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2026:KHC:17974 WP No. 6583 of 2026 THIS PETITION COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE S SUNIL DUTT YADAV ORAL ORDER Sri. K. Hemakumar, learned Additional Government Advocate accepts notice for the respondent. 2. The petitioner has sought for the setting aside of the order of adjudication dated 29.04.2024. It is the case of the petitioner that due to bona-fide reasons, petitioner could not participate in the proceedings and such lapse may be condoned and petitioner may be granted an opportunity to make out reply to the show- cause notice and demonstrate the reconciliation between the GSTR-3B returns as compared to GSTR-2A returns. 3. It is the case of the petitioner that reconciliation would be demonstrated by appropriate material to be placed, if opportunity is granted and that lapse on the petitioner's part may be condoned. - 3 - HC-KAR NC: 2026:KHC:17974 WP No. 6583 of 2026 4. Perused the order at Annexure-A. The authority has proceeded for adjudication upon scrutiny of returns, noticing certain discrepancies in availing of ITC and noticing discrepancy between GSTR-3B and the declaration made by the supplier as per GSTR-2A. The authority has also noticed that the petitioner has not supplied any reply nor any objections to the alleged discrepancy as made out in the show-cause notice. Adjudication is concluded on the basis of material available by the authority. 5. Taking note of the assertion that the petitioner has material and would demonstrate the discrepancy allegedly noticed by the authority between GSTR-3B returns as compared to GSTR-2A returns uploaded by the supplier, it would meet ends of justice by setting aside the order of adjudication and remitting the matter for fresh consideration, by reserving liberty to the petitioner to make out reply to the show-cause notice. - 4 - HC-KAR NC: 2026:KHC:17974 WP No. 6583 of 2026 6. Accordingly, the order of adjudication at Annexure-A is set aside. Matter is remitted in terms of the observation made above. Petitioner to appear before the respondent without further notice on 04.05.2026. All contentions are kept open. 7. Petitioner is put on terms by directing to pay 10% of the tax demand within three weeks from today. Accordingly, petition is disposed of. SD/- (S SUNIL DUTT YADAV) JUDGE MCR