IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 9^TH DAY OF MARCH, 2026 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 21130 OF 2022 (T-RES)

BETWEEN:

M/S HIVELOOP TECHNOLOGY PRIVATE LIMITED A COMPANY INCORPORATED UNDER THE PROVISIONS OF THE COMPANIES ACT 2013 NO.1090 G, 18^TH CROSS, 14^TH MAIN, SECTOR 3, HSR LAYOUT, BENGALURU – 560 102.

THROUGH ITS AUTHORISED REPRESENTATIVE, MR LALIT RAMAN C V.

…PETITIONER (BY SRI. TARUN GULATI, SENIOR COUNSEL FOR SRI. PRADEEP NAYAK, ADVOCATE)

AND:

1. THE ADDITIONAL DIRECTOR Digitally signed DIRECTORATE GENERAL OF GST INTELLIGENCE, by CHANDANA BENGALURU ZONAL UNIT, B M DIRECTORATE GENERAL OF GST INTELLIGENCE, Location: H igh Court of BENGALURU ZONAL UNIT, Karnataka OFFICE OF THE PRINICIPAL ADDITIONAL DIRECTOR GENERAL NO.112, S P ENCLAVE, ADJACENT TO KARNATAKA BANK K H ROAD, BENGALURU-560 027.

2. JOINT/ADDITIONAL COMMISSIONER OF CENTRAL TAX CHENNAI SOUTH CENTRAL TAX COMMISSIONERATE 692, M H U COMPLEX ANNA SALAI, NANDANAM, CHENNAI-600 035.

3. DEPUTY /ASSISTANT COMMISSIONER OF CENTRAL TAX SD 5 DIVISION BENGALURU SOUTH CENTRAL TAXES COMMISSIONERATE, BENGALURU-560 027.

4. THE COMMERCIAL TAX OFFICER DGSTO-4, AUDIT 4.8, KARNATAKA COMMER