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. KISHORE KUNAL, SMT. ANKITA PRAKASH, SRI. ANUJ KUMAR AND SRI. PRADEEP NAYAK, ADVOCATES)

AND:

1. THE ADDITIONAL DIRECTOR Digitally signed by DIRECTORATE GENERAL OF GST INTELLIGENCE, CHANDANA BENGALURU ZONAL UNIT, B M DIRECTORATE GENERAL OF GST INTELLIGENCE, BENGALURU ZONAL UNIT, Location:

High Court OFFICE OF THE PRINICIPAL of Karnataka 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.

Retyped and replaced vide Court order dated 16.04.2026

3. DEPUTY /ASSISTANT COMMISSIONER OF CENTRAL TAX SD 5 DIVISION BENGALURU SOUTH C