Reserved on : 12.03.2026 Pronounced on : 09.04.2026 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 9^TH DAY OF APRIL, 2026 PRESENT THE HON'BLE MR. JUSTICE S.G.PANDIT AND THE HON'BLE MR. JUSTICE K. V. ARAVIND SALES TAX APPEAL No. 20 OF 2025 BETWEEN:

1. M/S. EMJAY ENGINEERING COMPANY, No.70, 1^ST CROSS, 2^ND A MAIN, DOMLUR LAYOUT, BENGALURU-560 071, (REPRESENTED BY ITS PROPRIETRIX)

SMT. MEENAKSHI JACOB, AGED ABOUT 71 YEARS.

…APPELLANT (BY SRI K. M. SHIVAYOGISWAMY, ADVOCATE)

Digitally signed by VINUTHA B AND:

S Location: High Court of 1. THE ADDITIONAL COMMISSIONER OF Karnataka COMMERCIAL TAXES, (SMR)-3, V.T.K.-1, 8^TH FLOOR, GANDHI NAGAR, BENGALURU-560 009.

…RESPONDENT (BY SRI ADITYA VIKRAM BHAT, AGA)

THIS STA IS FILED UNDER SECTION 64(1) OF KARNATAKA VALUE ADDED TAX ACT 2003 AGAINST THE ORDER DATED 30.03.2025 PASSED IN CAS No.345441054 AD SMR ON THE FILE OF THE ADDITIONAL COMMISSIONER OF COMMERCIAL TAXES, (SMR) - 3, BENGALURU AND MODIFYING THE ORDER PASSED BY THE FAA VIDE APPEAL No.KVAT.A.P. 81/2020-21 DATED 22.01.2021 BEING ERRONEOUS ILLEGAL AND IMPROPER INSOFAR AS PREJUDICIAL TO THE INTEREST OF THE GOVERNMENT REVENUE.

THIS APPEAL HAVING BEEN HEARD AND RESERVED FOR JUDGMENT, COMIN