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2026 Supreme(Online)(Kar) 20184

THE HIGH COURT OF KARNATAKA
S.G.PANDIT AND K. V. ARAVIND
M/S ATRIA CONVERGENCE TECHNOLOGIES LTD – Appellant
Versus
THE DEPUTY COMMISSIONER OF COMMERCIAL TAXES (AUDIT) – Respondent
STRP 1/2026



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NC: 2026:KHC:17197-DB STRP No. 1 of 2026

HC-KAR

IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 26TH DAY OF MARCH, 2026

PRESENT

THE HON'BLE MR. JUSTICE S.G.PANDIT

AND

THE HON'BLE MR. JUSTICE K. V. ARAVIND

SALES TAX REVISION PETITION No. 1 OF 2026

BETWEEN:

1. M/S. ATRIA CONVERGENCE TECHNOLOGIES LTD., IIIRD FLOOR, GOLDEN HEIGHTS, No.1/2, 59TH 'C' CROSS,

4TH 'M' BLOCK, RAJAJINAGAR, BENGALURU - 560 010.

(A PRIVATE LIMITED COMPANY REGISTERED UNDER THE COMPANIES ACT, 2013 AND REPRESENTED BY MR. VATS SAWHNEY.....)

…PETITIONER Digitally (BY SRI. PRASHANTH R., ADVOCATE)

signed by VINUTHA B S Location: AND:

High Court of Karnataka

1. THE DEPUTY COMMISSIONER OF COMMERCIAL TAXES (AUDIT)-2.4.,

DVO-2, BENGALURU.

R.R. NAGAR, BENGLURU

2. THE JOINT COMMISSIONER OF COMMERCIAL TAXES, (APPEALS)-2,

BMTC, SHANTHINAGAR, BENGALURU - 560 027.

…RESPONDENTS (BY SRI ADITYA VIKRAM BHAT, AGA)

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NC: 2026:KHC:17197-DB STRP No. 1 of 2026

HC-KAR

THIS STRP IS FILED UNDER SECTION 65(1) OF THE KARNATAKA VALUE ADDED TAX ACT, 2003 AGAINST THE JUDGMENT DATED 27.02.2025 PASSED IN STA.No.128/2022 ON THE FILE OF KARNATAKA APPELLATE TRIBUNAL AT

BANGALORE AND ETC.,

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

CORAM: HON'BLE MR. JUSTICE S.G.PANDIT and

HON'BLE MR. JUSTICE K. V. ARAVIND

ORAL ORDER

(PER: HON'BLE MR. JUSTICE K. V. ARAVIND)

Heard Sri R. Prashanth, learned counsel for the

petitioner-Assessee and Sri Aditya Vikram Bhat, learned

Additional Government Advocate for the respondent-Revenue.

2. This Sales Tax Revision Petition is filed under Section 65(1) of the Karnataka Value Added Tax Act, 2003 by the assessee, impugning the order dated 27.02.2025 passed in STA No.128/2022 by the Karnataka Appellate Tribunal, Bengaluru

(for short, “the Tribunal”).

3. The petitioner–assessee is a private limited company registered under the provisions of the Central Sales Tax Act, 1956 (for short, “the CST Act”), engaged in the business of

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NC: 2026:KHC:17197-DB STRP No. 1 of 2026

HC-KAR

cable distribution, network operations, including local cable operations, multi-system operations, digital TV services, and

internet services.

3.1 The adjudicating authority concluded the assessment on 28.09.2020, determining the tax and interest payable. The assessee filed a rectification application, which was partly allowed. However, the claim for concession in respect of inter-

State stock transfers was rejected for want of statutory forms.

3.2 Aggrieved by the order passed on rectification, the assessee preferred an appeal before the Joint Commissioner of Commercial Taxes (Appeals)-2, Bangalore (First Appellate Authority). The First Appellate Authority dismissed the appeal, confirming the order of rectification. On further appeal, the

Tribunal also confirmed the said order and rejected the appeal.

4. Sri Prashanth, learned counsel for the petitioner, submits that the ‘C’ and ‘F’ Forms were not furnished along with the returns within the prescribed time, as the same were not made available by the concerned dealers/vendors. It is further submitted that the petitioner had no knowledge of the

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NC: 2026:KHC:17197-DB STRP No. 1 of 2026

HC-KAR

requirement to produce the said forms within the stipulated time. It is also contended that the ‘C’ and ‘F’ Forms were available in the e-mail ID of one of the employees who had left the company, and therefore, the petitioner was unable to

submit the same within the prescribed time.

4.1 Learned counsel submits that, if an opportunity is granted, the said ‘C’ and ‘F’ Forms would be produced before the adjudicating authority. With the above submissions, learned counsel prays that the impugned order be set aside and the matter be remitted to the adjudicating authority, with liberty to

the petitioner to produce the said forms.

5. Per contra, Sri Aditya Vikram Bhat, learned Additional Government Advocate for the respondent, submits that the production of ‘C’ and ‘F’ Forms within the prescribed period of three m

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