- 1 - HC-KAR NC: 2026:KHC:14339 WP No. 7796 of 2026 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 10TH DAY OF MARCH, 2026 BEFORE THE HON'BLE MR. JUSTICE S SUNIL DUTT YADAV WRIT PETITION NO. 7796 OF 2026 (T-RES) BETWEEN: 1. M/S RIZMAQ INTERNATIONAL PVT LTD A COMPANY INCORPORATED UNDER THE COMPANIES ACT, 2013 REPRESENTED HEREIN BY ITS DIRECTOR, SHRI SHAIKH SAMEER AHMED, RESIDING AND HAVING OFFICE AT NO. 93/44, 8TH CROSS, OPPOSITE METHODIST CHURCH, WILSON GARDEN, BENGALURU - 560 027 … PETITIONER (BY SRI. SANDEEP HUILGOL., ADVOCATE) AND: 1. COMMERCIAL TAX OFFICER LSGTO - 040 BANGALORE 6TH FLOOR, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, KORAMANGALA BENGALURU - 560 095 … RESPONDENT (BY SRI. HEMA KUMAR K., AGA) Digitally signed by VIJAYA P Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2026:KHC:14339 WP No. 7796 of 2026 THIS W.P. IS FILED UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA, PRAYING TO I. QUASHING THE IMPUGNED ADJUDICATION ORDER DATED 30.12.2024 BEARING NO. CTO/LGSTO-040/R1VS3B/2024-25 PASSED BY THE RESPONDENT UNDER SECTION 73 OF THE KARNATAKA GOODS AND SERVICES TAX ACT, 2017/ CENTRAL GOODS AND SERVICES TAX ACT, 2017 READ WITH SECTION 6 OF CENTRAL GOODS AND SERVICES TAX ACT, 2017 AND SECTION 20 OF INTEGRATED GOODS AND SERVICES TAX ACT, 2017 FOR THE TAX PERIODS APRIL 2020 TO MARCH 2021 (ANNEXURE-A) AND ETC. 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 The petitioner has called in question the validity of the order of adjudication at Annexure-A as well as Summary of the Order at Annexure-A1 and has sought for stay of recovery proceedings and set aside the consequential recovery proceedings. 2. Perused the order of adjudication. It is noticed that the order is passed while observing that the assessee has not availed of opportunities extended and has not filed the written submissions or objections. It is also submitted - 3 - HC-KAR NC: 2026:KHC:14339 WP No. 7796 of 2026 that the petitioner has not availed of opportunity of personal hearing. The authority has concluded the proceedings on the basis of materials provided without any reply on the part of the petitioner. 3. The petitioner submits that petitioner had paid tax for the relevant period however, was not in a position to reconcile regarding outward taxable supplies as per GSTR-1 and GSTR-3. Petitioner submits that due to ill-health, eventual demise of his mother who was also the Director, the other Director was not in a position to participate in the proceedings. 4. In light of the points made out and taking note of the assessment of tax for the relevant period, the order of adjudication at Annexure-A as well as Summary of the Order at Annexure-A1 are set aside and the matter is remitted back to the stage of reply to the show-cause notice dated 27.09.2024. - 4 - HC-KAR NC: 2026:KHC:14339 WP No. 7796 of 2026 5. In light of setting aside of the order of adjudication at Annexure-A as well as Summary of the Order at Annexure-A1, the authorities are directed to rescind the bank attachment forthwith. 6. Petitioner to appear before the respondent without further notice on 15.04.2026. All contentions are kept open. Sd/- (S SUNIL DUTT YADAV) JUDGE NP