- 1 - HC-KAR NC: 2026:KHC:31053 WP No. 18133 of 2026 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 23RD DAY OF JUNE, 2026 BEFORE THE HON'BLE MR. JUSTICE B M SHYAM PRASAD WRIT PETITION NO. 18133 OF 2026 (T-RES) BETWEEN: M/S MACHIMADA PONNAPPA CHANDRAVERMA PROPRIETOR OF M/S. SOUTH COORG SECURITY SERVICES NO.2, MANJUNATHA NILAYA, KATHRIGUPPE MAIN ROAD 6TH CROSS, BANASHANKARI III STATE, BANGALORE URBAN, KARNATAKA - 560085 …PETITIONER (BY SRI. VENKATANARAYANA G.M.,ADVOCATE) AND: THE COMMISSIONER OF CENTRAL TAXES CENTRAL EXCISE AND SERVICE TAX, GST COMMISSIONERATE BENGALURU NORTH-WEST, 2ND FLOOR, SOUTH WING, Digitally signed by VANAMALA N Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2026:KHC:31053 WP No. 18133 of 2026 BMTC BUS STAND COMPLEX, SHIVAJINAGAR, BENGALURU 560051. …RESPONDENT (BY SRI. ARAVIND V. CHAVAN, ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO ISSUE A WRIT OF CERTIORARI, OR ANY OTHER ORDER, OR DIRECTION QUASHING THE IMPUGNED ORDER (ORIGINAL) VIDE ORDER SL. NO. 167/2023-24 BEARING DIN- 20240357YU0000000084 DATED 30.03.2024 (ANNEXURE-A) PASSED BY RESPONDENT NO. 1, DEMANDING SERVICE TAX OF RS.14,11,821/- ALONG WITH INTEREST AND PENALTY FOR THE FINANCIAL YEAR 2015-16 TO 2017-18 (UPTO JUNE, 2017). THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE B M SHYAM PRASAD - 3 - HC-KAR NC: 2026:KHC:31053 WP No. 18133 of 2026 ORAL ORDER The petitioner is aggrieved by the order dated 28.03.2024 [issued on 30.03.2024] under Section 85 of the Finance Act, 1994 and is based on the information received from the Central Board of Direct Taxes based on an arrangement with the Central Board of Indirect Taxes. The petitioner has not had an opportunity. This Court, in similar circumstances, has intervened to restore the proceedings for adjudication in the light of the decision of this Court in M/s. Karnataka Chinmaya Seva Trust Vs. Joint Commissioner of Central Tax in W.P. No.11154/2023 and connected matters dated 03.07.2024. Mr. Aravind V. Chavan, the learned Standing counsel who accepts notice for the respondent, submits that after the afore decision, the jurisdictional officers have been conferred with the - 4 - HC-KAR NC: 2026:KHC:31053 WP No. 18133 of 2026 jurisdiction to extend an opportunity and then pass just orders. At this stage, Mr. Venkatanarayana G M, the learned counsel for the petitioner, submits that the recipient of the services would be liable to pay tax in terms of the Notification No.30/2012-Service Tax dated 20.06.2012. Mr. Venkatanarayana G M and Mr. Aravind V. Chavan, the learned counsels for the parties, are heard and the petition stands disposed of in the following terms. ORDER [A] The petition is allowed-in-part and the impugned Order-in-Original dated 28.03.2024 [issued on 30.03.2024] [Annexure - A] is quashed restoring the proceedings to the Assistant Commissioner of Central Tax, West Division-5, GST West Commissionerate, Bengaluru for reconsideration. - 5 - HC-KAR NC: 2026:KHC:31053 WP No. 18133 of 2026 [B] The petitioner shall, without further notice, file response, if any, with the Assistant Commissioner of Central Tax, West Division-5, GST West Commissionerate, Bengaluru by 20.07.2026 even without waiting for a certified copy of this order. [C] The Assistant Commissioner of Central Tax, West Division-5, GST West Commissionerate, Bengaluru shall consider all the circumstances without non-suiting the petitioner on the ground of delay. RB Sd/- (B M SHYAM PRASAD) JUDGE