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2025 Supreme(Online)(Kar) 33308

KARNATAKA HIGH COURT
S.R.KRISHNA KUMAR, J
M/S COLUMBIA SPORTSWEAR INDIA SOURCING PVT. LTD. – Appellant
Versus
UNION OF INDIA MINISTRY OF FINANCE – Respondent


Advocates:
For the Appellants/Petitioners: SRI. V. RAGHURAMAN, SENIOR COUNSEL, SRI. RAGHAVENDRA C. R., SRI. BHANUMURTHY J.S.
For the Respondents: SRI. MADANAN PILLAI R., SRI. ARAVIND V.CHAVAN, SRI. KUMAR M. N., SRI. JEEVAN J. NEERALGI

Table of Content
1. petitioner provides services as a separate legal entity. (Para 2 , 3)
2. characterization of petitioner’s services not as intermediary. (Para 6 , 7 , 8 , 9 , 10)
3. definition of intermediary services requires more than two parties. (Para 11 , 12 , 13 , 14)

ORAL ORDER

In W.P.No.12116/2024, petitioner seeks for the following reliefs:-

“(A) Issue a writ of certiorari or any other writ or direction or order to quash impugned Order-in-Original No.34/2022-23 dated 01.07.2022 bearing DIN: 202207570000006655 enclosed as Annexure A for the reasons stated in the grounds.

(B) Issue a writ of certiorari or any other writ or direction or order to quash impugned Order-in-Original No.104/2022-23ND3 dated 28.03.2023 bearing DIN:2023035700000000AB77 enclosed as Annexure B for the reasons stated in the grounds.

(C) Writ of declaration or any other appropriate writ or direction to declare that the provisions of Section 8 of INTEGRATED GOODS AND SERVICES TAX ACT, 2017 , enclosed as Annexure C, as unconstitutional for the reasons stated in the grounds.

(D) Writ of declaration or any other appropriate writ or direction to declare that the provisions of Section 13 (8) (b) of INTEGRATED GOO

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