IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 28^TH DAY OF NOVEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 16900 OF 2023 (T-RES)

BETWEEN:

IDP EDUCATION INDIA PVT LTD A COMPANY UNDER THE COMPANIES ACT (1), 1956, AND HAVING ITS REGISTERED OFFICE AT

22/9, BERETANA AGRAHARA, HOSUR MAIN ROAD, BANGALORE - 560100 AND REPRESENTED BY ITS HEAD OF TAXATION - SOUTH ASIA MS. PALLAVI SOOD …PETITIONER (BY SRI. KUMAR HARSHAVARDHAN, SMT PREETHA MAHADEVAN AND SRI. BHARATH JANARTHANAN, ADVOCATES)

AND:

Digitally signed by 1. THE UNION OF INDIA SHARADAVANI B THROUGH ITS SECRETARY Location: High DEPARTMENT OF REVENUE Court of MINISTRY OF FINANCE, GOVERNMENT Karnataka OF INDIA, CENTRAL SECRETARIAT, NORTH BLOCK, NEW DELHI -110001.

2. ADDITIONAL COMMISSIONER OF GST APPEALS-II, BENGALURU, TRAFFIC TRANSIT MANAGEMENT CENTRE, BMTC BUILDING, 4TH FLOOR, ABOVE BMTC BUS STAND, DOMLUR, OLD AIRPORT ROAD BENGALURU - 560071

3. ASSISTANT COMMISSIONER OF CENTRAL TAX NORTH DIVISION-I, NORTH COMMISSIONERATE, NO.-29/2, CRESCENT ROAD, 3RD FLOOR, BASAVESWARA BUILDING, BANGALORE - 560001 …RESPONDENTS (BY SMT. SHUBHA.S, CGC FOR R1;

SRI. ARAVIND V.CHAVAN, ADVOCATE FOR R2 AND R3)

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THIS WRIT