IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 13^TH DAY OF FEBRUARY, 2026 BEFORE THE HON'BLE MR. JUSTICE S SUNIL DUTT YADAV WRIT PETITION NO. 4665 OF 2026 (T-RES)

BETWEEN:

SLN ENTERPRISES A PROPRIETORSHIP CONCERN OF SHRI NARSIMHA NARESH SON OF SHRI NARASIMHA AGED 33 YEARS, HAVING OFFICE AT

174 / 2 , 1^ST MAIN ROAD LINGAIAH ROAD, SESHADRIPURAM BENGALURU - 560 020 EMAIL:SRIVATSALAW@GMAIL.COM MOB: +91 8971470774 …PETITIONER (BY SRI. PRADYUMNA HEJIB, ADVOCATE)

AND:

Digitally signed 1. THE ADDITIONAL COMMISSIONER by SHARADAVANI OF CENTRAL TAX, BENGALURU NORTH B Location: High GST COMMISSIONERATE Court of Karnataka HMT BHAVAN, GANGA NAGAR BENGALURU - 560 032

2. THE COMMISSIONER OF CENTRAL TAX (APPEALS-II)

4^TH FLOOR, TTMC-BMTC COMPLEX HAL AIRPORT ROAD DOMMALURU, BENGALURU - 560 071

3. THE ASSISTANT COMMISSIONER OF CENTRAL TAX, NORTH DIVISION - 3 HMT BHAVAN, GANGA NAGAR BENGALURU - 560 032 …RESPONDENTS (BY SRI. AKASH B. SHETTY, ADVOCATE)

THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO (A) ISSUE A WRIT IN THE NATURE OF CERTIORARI OR ANY OTHER APPROPRIATE WRIT/S TO QUASH THE IMPUGNED ORDER- IN-ORIGINAL BEARING NO. 08/ST/2022-23 (DIN 2022 0557 YW0000221602) DATED 20.05.2022, PASSED BY THE FIRST RESPONDENT (ANNEXURE -A) (B) GRANT SUCH OTHER ORDER OR DIRECTION AS DEEMED FIT IN THE FACTS AND CIRCUMSTANCES OF THE CASE IN THE INTEREST OF JUSTICE.

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

CORAM: HON'BLE MR. JUSTICE S SUNIL DUTT YADAV

ORAL ORDER

Sri. Akash B. Shetty, learned counsel accepts notice of the respondents.

2. The present petition has been filed seeking issuance of writ of certiorari to set aside the impugned Order-in-Original at Annexure-'A', dated 20.05.2022 passed by respondent No.1.

3. It is the contention of the petitioner that he is engaged with the activity of solid waste or municipal waste disposal as per the work orders by the Bruhath Bengaluru Mahanagara Palike ['the BBMP' for short].

4. It is the case of the petitioner that services when provided to a Government or local authority, wherein, the work being carried out is work which ordinarily entrusted to a municipality in relation to, public health, sanitation, conservancy, solid waste management, or slum improvement and upgradation, such services are exempt from levy of service tax by the Central Government vide Entry No.25(a) of Notification No. 25/2012-S.T., dated 20.06.2012.

5. It is the further case of the petitioner that there is exemption which the respondents-Authorities are required to examine and accordingly petitioner has no liability to discharge service tax as demanded. Petitioner submits that despite the said facts having been brought before the respondents-Authorities relying on exemption notification, respondents- Authorities have not properly appreciated the legal contention raised.

6. It is submitted that the co-ordinate bench in W.P.No.9522/2021 and other connected matters disposed of on 20.02.2025, in the case of identically situated assessees who were executing similar work orders, this Court has passed certain directions after expressing opinion on certain aspects, and on parity petitioner may be treated on same terms.

7. It is submitted that matter may be remanded while directing the respondents-Authorities to take note of the observations made in W.P.No.9522/2021 and other connected matters referred to above.

8. Learned counsel Sri. Akash B. Shetty appearing for the respondents submits that the order dated 20.02.2025 passed in W.P.No.9522/2021 and other connected matters is a matter of record and the Court may pass appropriate orders in the facts of the present case.

9. Perused the order dated 20.02.2025 passed in W.P.No.9522/2021 and other connected matters.

10. Assertion of the petitioner that, it is similarly situated as that of the assessees who were petitioners in the said petitions, prima facie requires acceptance. The observations made in the said order are extracte