IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 24^TH DAY OF NOVEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO.30948 OF 2025 (T-RES)

BETWEEN:

M/S RELY FAB SOLUTIONS NO.163, 10^TH MAIN, 3^RD PHASE, PEENYA INDUSTRIAL AREA, BENGALURU - 560 058 REPRESENTED BY ITS PARTNER, SRI RAGHU D J.

…PETITIONER (BY SRI. NEHA ALUR FOR SRI. ATUL K. ALUR, ADVOCATES)

AND:

1. STATE OF KARNATAKA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF FINANCE GOVERNMENT OF KARNATAKA, AMBEDKAR VEEDHI, BENGALURU – 560 001.

2. THE COMMISSIONER OF COMMERCIAL TAXES, Digitally VANIJYA THERIGE KARYALAYA, signed by KALIDASA MARG, GANDHI NAGAR, MADHURI S BENGALURU – 560 009.

Location :

High Court of

3. THE ASSISTANT COMMISSIONER Karnataka OF COMMERCIAL TAXES, LGSTO-75, 1^ST FLOOR KIADB BUILDING, 14^TH CROSS, 2^ND STAGE, PEENYA, BENGALURU – 560 058.

…RESPONDENTS (BY SMT. JYOTHI M. MARADI, HCGP)

THIS W.P IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO ISSUE A WRIT OF CERTIORARI OR WRIT IN THE NATURE OF CERTIORARI QUASHING THE NOTICE ISSUED IN FORM GST DRC-13 DATED 07/03/2024 AT ANNEXURE-F ISSUED BY RESPONDENT-3 VIDE NO.ACCT/LGSTO-75/DRC-13/2023-24 INSOFAR AS THE PETITIONER IS CONCERNED AND ETC.

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

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

ORAL O RDER

In this petition, petitioner seeks the following reliefs:

“a) Issue a writ of certiorari or writ in the nature of certiorari quashing the notice issued in Form GST DRC-13 dated 07/03/2024 at Annexure-F issued by respondent -3 vide No.ACCT/LGSTO-75/DRC-13/2023-24 insofar as the petitioner is concerned.

b) Issue a writ of certiorari or writ in the nature of certiorari quashing the notice issued in FORM GST DRC-13 dated 27/04/2023 at Annexure-E issued by respondent-3 vide No.ACCT/LGSTO-DRC-13/2023-24 insofar as the petitioner is concerned.

c) Issuing a writ of mandamus or a writ in the nature of mandamus directing the Bank Authorities to defreeze the bank account insofar as the petitioner is concerned.

d) Issuing a writ of mandamus or a writ in the nature of mandamus directing the respondent-3 to withdraw the GST-13 notices issued to the Karnataka Bank and Axis Bank Ltd., forthwith at Annexure – E & F insofar as the petitioner is concerned.

e) Issue any other directions as this Hon’ble Court deems fit to pass in the facts and circumstances of the case in the interest of justice and equity including the cost of the writ petition.”

2. Heard learned counsel for the petitioner and learned counsel for the respondents and perused the material on record.

3. A perusal of the material on record will indicate that on

17.02.2022 and 22.03.2023, 3^rd respondent issued notice in Form GST ASMT-10 to the petitioner, who did not submit any reply to the same, as a result of which, 3^rd respondent issued one more notice dated 11.10.2023 under Section 47(1) of the KGST Act calling upon the petitioner to pay an amount of Rs.8,900/- and since the petitioner did not reply to the same also, respondents have issued the impugned bank attachment notice at Annexures – E and F dated 27.04.2023 and 07.03.2024, aggrieved by which the petitioner is before this Court by way of the present petition. It is submitted that if the impugned notices at Annexures – E and F are set aside and one more opportunity is provided to the petitioner, the petitioner would submit replies to the notices at Annexures – B and C and respondents may be directed to consider the same and proceed further in accordance with law.

4. The said submission is placed on record.

5. Under these circumstances, since it is an undisputed fact that petitioner did not submit reply to the notices at Annexures – B and C, I deem it just and appropriate to allow the petition and remit the matter back to the 3^rd respondent for reconsideration afresh by issuing certain directions.

6. In the result, I pass the following:

ORDER (i) The petition is hereby allowed (ii) The impugned notices at Anne