- 1 - HC-KAR NC: 2026:KHC:35044 WP No. 8981 of 2026 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 10TH DAY OF JULY, 2026 BEFORE THE HON'BLE MR. JUSTICE B M SHYAM PRASAD WRIT PETITION NO. 8981 OF 2026 (T-RES) BETWEEN: M/S. NUMEROS MOTORS PRIVATE LIMITED, A COMPANY INCORPORATED UNDER THE COMPANIES ACT, 2013 REPRESENTED HEREIN BY SMT. CHANDRAKALA C R D/O C K RAMASUBRAMANI AGED ABOUT 44 YEARS RESIDING AT PRAKRUTHI, 53, 4TH CROSS, OPPOSITE TO RN SQUARE APARTMENT, GIC EMPLOYEES LAYOUT, KEMBATHAHALLI, ANJANAPURA, BENGALURU DISTRICT, KARNATAKA- 560108 HAVING ITS REGISTERED OFFICE AT 1ST FLOOR, 58, INNOVATIONS, 15TH CROSS, 2ND PHASE, JP NAGAR, BENGALURU URBAN, KARNATAKA 560078. …PETITIONER (BY SRI. SANDEEP HUILGOL., ADVOCATE) Digitally signed by VANAMALA N Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2026:KHC:35044 WP No. 8981 of 2026 AND: ASSISTANT COMMISSIONER OF COMMERCIAL TAX, LGSTO-091, BENGALURU 1ST FLOOR, BMTC BUILDING, JAYANAGAR, 4TH BLOCK BENGALURU - 560011. …RESPONDENT (BY SRI.K. HEMA KUMAR., AGA) THIS WP IS FILED UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO QUASHING THE IMPUGNED REFUND REJECTION ORDER DATED 19.01.2026 BEARING REFERENCE NO. ACCT(LGSTO)- 91//2025-26 AND THE SUMMARY THEREOF DATED 30.01.2026 IN FORM GST RFD-06 BEARING NO. ZD2901261607919, PASSED AND ISSUED BY THE RESPONDENT REJECTING THE REFUND APPLICATION PERTAINING TO THE TAX PERIOD SEPTEMBER 2023 TO OCTOBER 2023 (ANNEXURE A AND A-1); II. QUASHING THE IMPUGNED REFUND SANCTION ORDER DATED 30.07.2025 BEARING REFERENCE NO. /2025-26 AND THE SUMMARY THEREOF IN FORM GST RFD-06 BEARING NO. ZD29072551244745, TO THE EXTENT IT REJECTS THE REFUND APPLICATION PERTAINING TO THE TAX PERIOD JANUARY 2023 (ANNEXURE 'B' AND 'B-1'); III. QUASHING THE IMPUGNED REFUND SANCTION ORDER DATED 30.07.2025 REFERENCE NO. /2025-26 AND THE SUMMARY THEREOF IN FORM GST RFD-06 BEARING NO. ZD290725124261G, TO THE EXTENT IT REJECTS THE REFUND APPLICATION PERTAINING TO THE TAX PERIOD FEBRUARY 2023 TO MARCH 2023 (ANNEXURE 'C' AND 'C-1'); IV. QUASHING THE IMPUGNED SUMMARY DATED 18.12.2025 IN FORM GST RFD-06 BEARING NO. ZD291225142095G, ISSUED BY THE RESPONDENT REJECTING THE REFUND APPLICATION PERTAINING TO THE TAX PERIOD APRIL 2023 TO JULY 2023 (ANNEXURE 'D'; V. DIRECT THE RESPONDENT TO FORTHWITH REMOVE/ DELETE THE - 3 - HC-KAR NC: 2026:KHC:35044 WP No. 8981 of 2026 DOCUMENT REFERRED TO AS A REFUND REJECTION ORDER UPLOADED ON THE GST PORTAL FOR THE PERIOD APRIL TO JULY 2023 BEARING REFERENCE NO. /2025-26, AS IT DOES NOT PERTAIN TO THE PETITIONER'S REFUND APPLICATION FOR THE SAID PERIOD AND INSTEAD REFERS TO AN ARN NO. AA291024065013N AND APPLICATION DATED 23.10.2024 WHICH WAS NEVER FILED BY IT (ANNEXURE 'D-1'); VI. DIRECT THE RESPONDENT TO FORTHWITH REFUND THE ENTIRE CLAIMED AMOUNTS, ALONG WITH APPLICABLE INTEREST THEREON. THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE B M SHYAM PRASAD ORAL ORDER The petitioner has called in question the Orders which relate to refusal of the petitioner's claim for refund under the Inverted Duty Structure as permissible under Section 54[3] of the Central Goods and Services Tax Act/Karnataka Goods and Services Tax Act, 2017 [for short ‘the CGST/KGST Act’]. These Orders relate to the tax periods between January 2023 and October 2023 excluding August 2023. The petitioner's request for refund for April to July 2023 and September and October 2023 [Annexures-D, D1, - 4 - HC-KAR NC: 2026:KHC:35044 WP No. 8981 of 2026 A and A1] is rejected entirely, and the petitioner’s request for refund for January to March 2023 [Annexures-B, B1, C and C1] is rejected partially. Sri Sandeep Huilgol, the learned counsel for the petitioner and Sri K Hema Kumar, the learned Additional Government Advocate, who accepts notice for the respondent, are heard on the following aspects for disposal of the petition. [A] The total rejection of the refund for the months between April to October 2023 [excluding August 2023] is without any reason and possibly because the petitioner has filed Reply beyond the time permitted but well within the date of the refund. [B] The partial rejection for January to March 2023 is recording that the petitioner has claimed Input Tax Credit on services with certain details in the tabular column that follow without any explanation. Further, this Court must also record that Annexure-D1 which must be part of Annexure-D [for - 5 - HC-KAR NC: 2026:KHC:35044 WP No. 8981 of 2026 April to July 2023] has details which do not relate to the petitioner. With these circumstances being undisputed, this Court must opine that there must be a limited interference setting aside the impugned Orders restoring the proceedings for reconsideration with liberty to the petitioner to file copies of the Reply/Additional Replies. In the light of the afore, the following ORDER [A] The petition is allowed in-part. [B] The impugned Refund Rejection Orders [i] dated 19.01.2026 [Annexure-A] and [ii] dated 30.01.2026 [Annexure-A1], [iii] dated 30.07.2025 [Annexures-B and B1], [iv] dated 30.07.2025 [Annexures-C and C1] [v] dated 18.12.2025 [Annexures-D] and [vi] dated 17.11.2025 [Annexure-D1]. - 6 - HC-KAR NC: 2026:KHC:35044 WP No. 8981 of 2026 [C] Each of these proceedings are restored to the respondent for fresh consideration. [D] The petitioner shall file copies of the Reply/Additional Reply if any by 24.08.2026 with the respondent without further notice. Sd/- (B M SHYAM PRASAD) JUDGE AN/-