IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 09^TH DAY OF APRIL, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R. KRISHNA KUMAR WRIT PETITION NO. 35114 OF 2024 (T-RES)

BETWEEN:

SJR PRIME CORPORATION PRIVATE LIMITED (A PRIVATE LIMITED COMPANY INCORPORATED UNDER THE COMPANIES ACT, 1956)

SURVEY NO. 8/2, THE HUB, AMBALIPURA, BELLANDURU, SARJAPUR MAIN ROAD, BENGALURU RURAL, BENGALURU - 560 103.

REP. BY ITS DIRECTOR, MR. JAYARAMA VIJAY REDDY, S/O JAYARAMA REDDY, AGED ABOUT 47 YEARS, OCCUPATION: DIRECTOR, RESIDING AT NO.8/2, 9, THE HUB, AMBALIPURA VILLAGE, BELLANDUR, SARJAPUR ROAD, SARJAPURA MAIN ROAD, BENGALURU - 560 103.

…PETITIONER Digitally signed by ARUNKUMAR M S (BY SRI. BALACHANDRAN B. S., ADVOCATE)

Location: HI GH COURT OF KARNATAKA AND:

1. THE SUPERINTENDENT OF CENTRAL TAX EED-8 RANGE, DIVISION-8, GST COMMISSIONERATE, BENGALURU EAST, 2^ND FLOOR, TTMC/BMTC BUILDING, OLD AIRPORT ROAD, DOMLUR, BENGALURU - 560 071.

2. THE ASSISTANT / DEPUTY COMMISSIONER OF CENTRAL TAX, EASTERN DIVISION - 8, GST COMMISSIONERATE, BENGALURU EAST, 5^TH FLOOR, TTMC/BMTC BUILDING, OLD AIRPORT ROAD, DOMLUR, BENGALURU - 560 071.

3. THE COMMISSIONER OF CENTRAL TAX EASTERN DIVISION - 8, GST COMMISSIONERATE, BENGALURU EAST, 5^TH FLOOR, TTMC/BMTC BUILDING, OLD AIRPORT ROAD, DOMLUR, BENGALURU - 560 071.

…RESPONDENTS (BY SRI. ARAVIND V. CHAVAN, ADVOCATE)

THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND

227 OF THE CONSTITUTION OF INDIA, PRAYING TO QUASH THE COMMUNICATION ISSUED BY THE RESPONDENT NO.2 ON 05.12.2023 IN GEXCOM/ADT/CAG/21/2023-CGST-RANGE-E-DIV-8- COMMRTE-BENGALURU(E) VIDE ANNEXURE-C; QUASH THE NOTICE DATED 30.07.2024 ISSUED BY THE RESPONDENT NO.2 TO THE PETITIONER'S BANK UNDER SECTION 79(1)(c) OF THE CGST ACT IN GST DRC-13 IN NOTICE NO.02/2023-24 (DRC-13) AND DIN: 20240757000000000D2A VIDE ANNEXURE-E; QUASH THE ORDER/COMMUNICATION DATED 08.11.2024 ISSUED BY THE RESPONDENT NO.2 IN DIN. 20241157000000666CA4 FOR THE PERIOD JULY-2017 TO MARCH- 2018 VIDE ANNEXURE-H; AND ETC.

THIS PETITION COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER:

CORAM: HON'BLE MR JUSTICE S.R.KRISHNA KUMAR

ORAL ORDER

In this petition, the petitioner seeks the following reliefs:

"i. Issue a writ of certiorari or any other writ as the Hon'ble High Court may deem fit and quash the following:

ANNEXURE-C: Impugned communication issued by the Respondent No.2 on 05.12.2023 in GEXCOM/ADT/CAG/21/2023-CGST-

RANGE-E-DIV-8-COMMRTE-Bengaluru(E).

ANNEXURE-E: Impugned notice dated 30.07.2024 issued by the Respondent No.2 to the Petitioner's bank under Section 79(1)(c) of the CGST Act in GST DRC-13 in Notice No.02/2023-24 (DRC-

13) and DIN: 20240757000000000D2A.

ANNEXURE-H: Impugned order/communication dated

08.11.2024 issued by the Respondent No.2 in DIN:20241157000000666CA4 for the period July-2017 to March-2018.

ii. To issue the writ of mandamus or any other appropriate writ in the nature of mandamus, order or direction, directing the respondent No.2 to lift the attachment placed on the bank Account No.32445027247 of the Petitioner maintained with State Bank of India, No.117, 7^th Block, Industrial Layout, Koramangala, Bengaluru-560034 for recovery of the outstanding interest payable in pursuance to garnishee notice dated 30.07.2024 issued by the respondent No.2 vide Annexure-E;

iii. To issue any other order(s), direction(s), writ(s) or any other relief(s) as the Hon'ble Court deems fit and proper in the facts and circumstances of the case and in the interest of justice."

2. Heard learned counsel for the petitioner and learned counsel for respondents and perused the material on record. 3. A perusal of the material on record will indicate that the prayer Nos.i and ii were earlier sought for by the petitioner in Writ Petition No.26351/2024, which was disposed of by this Court, by order dated 01.10.2024. The said order reads as under:

"ORAL ORDER In this petition, petitioner seeks the following reliefs:

“ i) issue a writ of certiorari or any other writ as the Hon’ble High Court may deem fi