IN THE HIGH COURT OF KARNATAKA AT BENGALURU

DATED THIS THE 17^TH DAY OF DECEMBER, 2025

BEFORE

THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR

WRIT PETITION NO. 38219 OF 2025 (T-RES)

BETWEEN:

EDUCATIONAL RATING AND ASSESSMENT FOUNDATION,

A SECTION 25 COMPANY INCORPORATED

UNDER COMPANIES ACT, 1956

REPRESENTED BY ITS DIRECTOR

SRI.M.R. JAYARAM

S/O LATE M.S. RAMAIAH AGED ABOUT 78 YEARS

5^TH AND 6^TH FLOOR, LAVELLE MANSION,

1/2, LAVELLE ROAD,

BENGALURU 560 001.

REGISTERED UNDER GST ACT

WITH GSTIN 29AAECE8273G1ZB

…PETITIONER

(BY SRI. ANNAMALAI S.,ADVOCATE)

AND:

1. UNION OF INDIA

Digitally signed

MINISTRY OF FINANCE,

by CHANDANA

REPRESENTED BY ITS SECRETARY,

B M

NORTH BLOCK, Location: High

NEW DELHI-110 001.

Court of

Karnataka

2. CENTRAL BOARD OF

INDIRECT TAXES AND CUSTOMS,

REPRESENTED BY ITS CHAIRPERSON,

NORTH BLOCK,

NEW DELHI-110 001.

3. THE ADDITIONAL DIRECTOR,

OFFICE OF THE PRINCIPAL

ADDITIONAL DIRECTOR GENERAL

OF GOODS AND SERVICES TAX INTELLIGENCE,

BENGALURU ZONAL

UNIT, NO. 112, K.H.ROAD,

SP ENCLAVE, ADJ. TO KARNATAKA BANK, BENGALURU-560 027.

4. THE JOINT COMMISSIONER OF CENTRAL TAXES, OFFICE OF COMMISSIONER OF CENTRAL TAX.

BENGALURU NORTH COMMISSIONERATE, HMT BHAVAN, GANGA NAGAR, BENGALURU-560 032.

5. THE COMMISSIONER OF CENTRAL TAX A