High Court of Karnataka7 July 2026

Bangalore Metro Rail Corporation Ltd. v. Karnataka Appellate Authority for Advance Ruling

For revenue

WRIT PETITION NO. 192 OF 2022 (T-RES)

The ruling in brief

Third-party petitioner lacked locus to challenge an AAR/AAAR ruling under Article 226, as such rulings bind only applicant therein and its jurisdictional authority; absent contractual GST classification or rate terms in respect of contract entered between petitioner and said applicant, no civil consequence arose, and writ jurisdiction could not rewrite contract

Provisions considered

Section 103, read with section 101, of Central Goods and Services Tax Act, 2017/Karnataka Goods and Services Tax Act, 2017 - Article 226 of Constitution of India, 1950

This summary is for general information and is not legal advice. Read the full decision and the applicable law before relying on it.

The ruling in brief

Related rulings

AAAR West Bengal15 Jul 2026

For revenue

Karam Chand Thapar & Bros (Coal Sales) Ltd., In re

Where appellant completed construction contracts and received final payments prior to GST regime, but later sought advance ruling regarding taxability of compensation received post-arbitration, since advance ruling provisions applies only to ongoing or proposed supplies, and not to completed transactions, application was not maintainable and ruling could not be sustained GST: Where WBAAR admitted and ruled on an application regarding classification and taxability, on appeal, AAAR could examine maintainability even though admission occurred under Section 98(2), as appellate jurisdiction under Section 101(1) allows consideration of legal questions including maintainability, despite no departmental appeal or specific challenge from appellant. GST: Where appellant completed works pre-GST, received arbitral award in 2023 with payments in 2024, invocation of Section 142(2)(a) for treating awarded sums as upward price revision was incorrect since arbitral award alone does not constitute upward revision, and whether components are consideration for supplies, revision, damages or other heads requires case-specific fact scrutiny outside advance ruling scope. GST: Where amounts awarded for services that were potentially taxable under erstwhile law but not actually taxed are considered in transitional provisions; mere non-payment of service tax under old regime does not by itself mandate levy of GST, as section 142(11)(a) intends to prevent double taxation based on leviability under earlier law, not actual payment

Supreme Court18 Sept 2026

For revenue

Manpar Icon Technologies v. Assistant Commissioner CGST Division

SLP was filed against order of High Court holding that where assessee assailed demand order and corrigendum to SCN including additional period in writ alleging illegality, since such issues involved factual examination of corrections under sections 160 and 161 and were already considered by adjudicating authority, in view of available alternate remedy of appeal, writ was not maintainable and petition was to be dismissed with liberty to avail appellate remedy; SC declined to interfere with HC order dismissing writ for alternative remedy and extended limitation, SLP was to be disposed of

Supreme Court7 Sept 2026

For assessee

PVCON Engineering Co. v. CGST and Central Excise, Bhopal

Notice issued in SLP filed against impugned order of High Court holding that where assessee construction contractor challenged penalty order for alleged irregular input tax credit on grounds of natural justice and jurisdiction after appeal was dismissed on limitation, since statutory appeal before GST Tribunal was enabled with additional grace period and Tribunal was competent to examine factual and legal grounds, writ petition under Article 226 could not substitute appellate remedy and same was to be dismissed with liberty to approach Tribunal

Related rulings

AAAR West Bengal15 Jul 2026

For revenue

Bangalore Metro Rail Corporation Ltd. v. Karnataka Appellate Authority for Advance Ruling

The ruling in brief

Provisions considered

Bangalore Metro Rail Corporation Ltd. v. Karnataka Appellate Authority for Advance Ruling

The ruling in brief

Provisions considered

Read the full analysis

Karam Chand Thapar & Bros (Coal Sales) Ltd., In re

Manpar Icon Technologies v. Assistant Commissioner CGST Division

PVCON Engineering Co. v. CGST and Central Excise, Bhopal

Read the full analysis