AND 2 OTHERS Reserved on : 20.02.2026 Pronounced on : 17.03.2026 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 17^TH DAY OF MARCH, 2026 PRESENT THE HON'BLE MR. JUSTICE S.G.PANDIT AND THE HON'BLE MR. JUSTICE K. V. ARAVIND WRIT APPEAL No. 110 OF 2026 (T-RES)

C/W WRIT APPEAL No. 119 OF 2026 (T-RES) WRIT APPEAL No. 122 OF 2026 (T-RES) WRIT APPEAL No. 126 OF 2026 (T-RES) WRIT APPEAL No. 140 OF 2026 (T-RES)

IN WA No. 110/2026 BETWEEN:

Digitally signed by VINUTHA B S 1. ASSISTANT COMMISSIONER OF CENTRAL TAXES Location: High NORTH WEST DIVISION-1, Court of Karnataka NORTH WEST COMMISSIONERATE, 2^ND FLOOR, BMTC COMPLEX, SHIVAJINAGAR BUS STAND, BENGALURU - 560 051.

2. CENTRAL BOARD OF INDIRECT TAXES AND CUSTOMS, REPRESENTED HEREIN BY THE CHAIRMAN DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, AND 2 OTHERS GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110 001.

3. THE UNION OF INDIA REPRESENTED HEREIN BY THE SECRETARY DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110 001.

…APPELLANTS (BY SRI ARAVIND V. CHAVAN, SENIOR STANDING COUNSEL)

AND:

1. M/S MERCK LIFE SCIENCE PRIVATE LIMITED REPRESENTED BY ITS AUTHORISED SIGNATORY MS. SNEHA PATIL, AGED ABOUT 35