- 1 - HC-KAR CNR: KAHC010311602026 NC: 2026:KHC:36484-DB WA No. 1302 of 2026 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 16TH DAY OF JULY, 2026 PRESENT THE HON'BLE MR. JUSTICE S.G.PANDIT AND THE HON'BLE DR. JUSTICE K.MANMADHA RAO WRIT APPEAL NO. 1302 OF 2026 (T-RES) BETWEEN: 1. ASSISTANT COMMISSIONER OF CENTRAL TAX CIRCLE-IV, CENTRAL TAX AUDIT-1 COMMISSIONERATE, 2ND FLOOR, BMTC, TTMC, BANASHANKARI, BENGALURU-560070. 2. ADDITIONAL COMMISSIONER OF CENTRAL TAX, CENTRAL TAX AUDIT-1 COMMISSIONERATE 2ND FLOOR, BMTC, TTMC, BANASHANKARI, BENGALURU – 560070. 3. SUPERINTENDENT OF CENTRAL TAX, SG-4. CENTRAL TAX AUDIT-1 COMMISSIONERATE, 2ND FLOOR, BMTC, TTMC, BANASHANKARI, BENGALURU – 560070. 4. DEPUTY/ASSISTANT COMMISSIONER OF CENTRAL TAX, RANGE CED-2, EAST DIVISION 2, BENGALURU EAST COMMISSIONERATE. TTMC/BMTC BUILDING, OLD AIRPORT ROAD, BENGALURU – 560071. Digitally signed by NANJUNDACHARI Location: High Court of Karnataka - 2 - HC-KAR CNR: KAHC010311602026 NC: 2026:KHC:36484-DB WA No. 1302 of 2026 5. ADDITIONAL/JOINT COMMISSIONER OF CENTRAL TAX, RANGE CED-2, EAST DIVISIONS 2, BENGALURU EAST COMMISSIONERATE, TTMC/BMTC BUILDING, OLD AIRPORT ROAD, BENGALURU-560071. 6. SUPERINTENDENT OF CENTRAL TAX, BENGALURU SOUTH COMMISSIONERATE, BENGALURU, 1ST FLOOR, C R BUILDING QUEENS ROAD, SHIVAJI NAGAR, BENGALURU-560001. 7. COMMISSIONER OF CENTRAL TAX (AUDIT) CENTRAL TAX AUDIT-1 COMMISSIONERATE, 2ND FLOOR, BMTC, TTMC, BANASHANKARI, BENGALURU – 560070. …APPELLANTS (BY SRI. UNNIKRISHNAN M.,ADVOCATE) AND: M/S. OZONE FACILITY MANAGEMENT PVT. LTD., REPRESENTED HEREIN BY ITS DIRECTOR MR. MEDIPALLI SREEHARI, HAVING ITS REGISTERED OFFICE AT NO.38, OZONE URBANA INFRA DEVELOPERS PVT. LTD., 2ND FLOOR, ULSOOR ROAD, BANGALORE – 560042. …RESPONDENT (BY SRI. SANDEEP HUILGOL.,ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT PRAYING TO SET ASIDE THE ORDER DATED 17/12/2025 PASSED BY THE LEARNED SINGLE JUDGE IN THE CASE OF WP NO.33952/2025 AND STAY THE OPERATION AND EFFECT OF THE ABOVE SAID ORDER DATED 17/12/2025 AT THE EARLIEST AND ETC. THIS APPEAL, COMING ON FOR ORDERS, THIS DAY, JUDGMENT WAS DELIVERED THEREIN AS UNDER: - 3 - HC-KAR CNR: KAHC010311602026 NC: 2026:KHC:36484-DB WA No. 1302 of 2026 CORAM: HON'BLE MR. JUSTICE S.G.PANDIT AND HON'BLE DR. JUSTICE K.MANMADHA RAO ORAL JUDGMENT (PER: HON'BLE MR. JUSTICE S.G.PANDIT) Heard learned counsel Sri.Raghunandan.K.S., for Sri.Unnikrishnan.M., learned counsel for appellants and learned counsel Sri.Sandeep Huilgol for respondent. Perused the entire writ appeal papers. 2. The respondent was before the learned Single Judge in W.P.No.33952/2025 questioning the common show cause notice issued under Section 74 of the CGST/KGST Act, 2017 for the tax periods 2019-20 to 2023-24. Learned Single Judge under impugned order dated 17.12.2025 allowed the writ petition and quashed the common show cause notice. However, liberty was reserved to initiated appropriate proceedings in accordance with law. - 4 - HC-KAR CNR: KAHC010311602026 NC: 2026:KHC:36484-DB WA No. 1302 of 2026 3. This Court in W.A.No.1751/2024 and connected matters by judgment dated 24.04.2026 has held that the consolidated/common show cause notice is permissible and wherever the matter was at the stage of submitting reply to the show cause notice, the matter was remitted back to the Adjudicating Authority to consider the objections and to pass appropriate order. 4. Following the above judgment dated 24.04.2026 in W.A.No.1751/2024, the present appeal needs to be allowed. Hence, the following: ORDER a) Writ appeal is allowed. b) Order dated 17.12.2025 in W.P.No.33952/2025 is set aside. c) The matter is remitted back to the Adjudicating Authority to receive objections and proceed further to pass - 5 - HC-KAR CNR: KAHC010311602026 NC: 2026:KHC:36484-DB WA No. 1302 of 2026 appropriate order in accordance with law. d) The respondent herein is granted four weeks time from the day this order is uploaded on the website of this Court, to file objections to the common show cause notice dated 03.09.2025 and 10.09.2025 issued under Section 74 of the CGST/KGST Act, 2017. Sd/- (S.G.PANDIT) JUDGE Sd/- (DR.K.MANMADHA RAO) JUDGE NC CT:bms List No.: 1 Sl No.: 20