- 1 - HC-KAR CNR: KAHC010301252026 NC: 2026:KHC:50840-DB WA No. 1272 of 2026 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 17TH DAY OF SEPTEMBER, 2026 PRESENT THE HON'BLE MR. VIBHU BAKHRU, CHIEF JUSTICE AND THE HON'BLE MRS. JUSTICE K.S. HEMALEKHA WRIT APPEAL NO.1272 OF 2026 (T-RES) BETWEEN: 1. UNION OF INDIA THROUGH ITS SECRETARY MINISTRY OF FINANCE DEPARTMENT OF REVENUE GOVERNMENT OF INDIA NORTH BLOCK, NEW DELHI-110001 (REP. BY THE FINANCE SECRETARY) 2. THE JOINT COMMISSIONER OF CENTRAL TAX BANGALORE NORTH GST COMMISSIONERATE NO.56, HMT BHAVAN, BELLARY ROAD, BENGALURU-560032. 3. THE COMMISSIONER OF COMMERCIAL TAXES (APPEALS-II), TRAFFIC TRANSIT MANAGEMENT CENTRE BMTC BUILDING, 4TH FLOOR, ABOVE BMTC BUS STAND DOMLUR OLD AIRPORT ROAD BENGALURU-560071. 4. THE ADDITIONAL DIRECTOR DIRECTORATE GENERAL OF GST INTELLIGENCE BENGALURU ZONAL UNIT OFFICE OF THE PRINCIPAL ADDITIONAL DIRECTOR GENERAL NO.112 SP ENCLAVE ADJACENT TO KARNATAKA BANK Digitally signed by C K LATHA Location: High Court of Karnataka - 2 - HC-KAR CNR: KAHC010301252026 NC: 2026:KHC:50840-DB WA No. 1272 of 2026 KH ROAD, BENGALURU-560027. 5. THE STATE OF KARNATAKA VIDHANA SOUDHA, BENGALURU-560001 REP. BY ITS FINANCE SECRETARY. 6. THE ASSISTANT COMMISSIONER OF COMMERCIAL TAXES LGSTO 20 DGSTO 01 NO.93 2ND FLOOR CUNNINGHAM ROAD, BENGALURU-560052. …APPELLANTS (BY SRI. UNNIKRISHNAN M., ADVOCATE) AND: M/S. KARNATAKA POWER CORPORATION LIMITED NO.82, SHAKTHI BHAVAN, RACE COURSE ROAD, BANGALORE-560001, REP. BY SHRI GAURAV GUPTA MANAGING DIRECTOR AGED ABOUT 58 YEARS IT IS A LIMITED COMPANY (STATE GOVERNMENT UNDERTAKING). …RESPONDENT (BY SRI. NAVEEN KUMAR K.S., ADVOCATE) THIS WRIT APPEAL IS FILED UNDER SECTION 4 OF THE KARNATAKA HIGH COURT ACT PRAYING TO SET ASIDE THE ORDER DATED 17.12.2025 PASSED BY THE LEARNED SINGLE JUDGE IN W.P.NO.34484/2025 (T-RES). THIS APPEAL, COMING ON FOR ADMISSION, THIS DAY, JUDGMENT WAS DELIVERED THEREIN AS UNDER: CORAM: HON'BLE MR. VIBHU BAKHRU, CHIEF JUSTICE and HON'BLE MRS. JUSTICE K.S. HEMALEKHA - 3 - HC-KAR CNR: KAHC010301252026 NC: 2026:KHC:50840-DB WA No. 1272 of 2026 ORAL JUDGMENT (PER: HON'BLE MR. VIBHU BAKHRU, CHIEF JUSTICE) 1. The appellants have filed the present appeal impugning an order dated 17.12.2025 [impugned order] passed by the learned Single Judge in Writ Petition No.34484/2025 [T-RES]. The respondent (writ petitioner) had filed the said petition assailing an order in appeal dated 06.02.2025 passed by respondent No. 3 (Commissioner of Commercial Tax Appeals-II). 2. According to the respondent, the order in appeal was contrary to the provisions of the Central Goods and Services Tax Act, 2017 and Karnataka Goods and Services Tax Act, 2017. One of the grounds raised by the respondent was that the proceedings were commenced pursuant to a notice for consolidated years issued under Sections 73 and 74 of the CGST Act. The aforesaid petition was allowed holding that the issue involved is covered by the decision of this Court in M/s Pramur Homes and Shelters vs The Union of India and Others1. 1 Writ Petition No.33081/2025 dated 11.12.2025 - 4 - HC-KAR CNR: KAHC010301252026 NC: 2026:KHC:50840-DB WA No. 1272 of 2026 3. The learned counsel for the appellants points out that the said decision in M/s Pramur Homes and Shelters (supra) was appealed by the Revenue before the Division Bench of this court in Writ Appeal No.407/2026. The said appeal was considered with a batch of other appeals which were allowed by an order dated 23.04.2026 [Writ Appeal No.1751/2024 and other connected matters]. Thus, the solitary ground on which the writ petition is allowed no longer holds good. 4. The learned counsel for the respondent states apart from the challenge to the show cause notice on the ground that it had bunched up different periods, there were other substantial grounds which were not considered by the learned Single Judge. The learned counsel for the appellants also does not controvert the said contention. 5. In view of the above, the present appeal is allowed. The impugned order is set aside. The Writ Petition being W.P.No. 34484/2025 is restored before the learned Single Judge for consideration of the other grounds of challenge. - 5 - HC-KAR CNR: KAHC010301252026 NC: 2026:KHC:50840-DB WA No. 1272 of 2026 6. List the said petition before the concerned Bench on 30.09.2026. 7. The pending interlocutory application stands disposed of. Sd/- (VIBHU BAKHRU) CHIEF JUSTICE Sd/- (K.S. HEMALEKHA) JUDGE CKL List No.: 1 Sl No.: 11