Full Judgment Text
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NC: 2026:KHC:15559
WP No. 39795 of 2025
HC-KAR
IN THE HIGH COURT OF KARNATAKA AT BENGALURU
TH
DATED THIS THE 17 DAY OF MARCH, 2026
BEFORE
THE HON'BLE MR. JUSTICE S SUNIL DUTT YADAV
WRIT PETITION NO. 39795 OF 2025 (T-RES)
BETWEEN:
M/S. FIERY DIGITAL IMAGING INDIA PRIVATE
LIMITED,
(FORMERLY KNOWN AS ELECTRONICS FOR
IMAGING INDIA PRIVATE LIMITED),
(A PRIVATE LIMITED COMPANY, REPRESENTED
BY ITS ASSISTANT MANAGER,
ACCOUNTING APAC GL,
MR. ADITHYA HJ,
GROUND AND FIRST FLOOR, EBONY BLOCK,
PHASE II, KALYANI PLATINA,
EPIP ZONE, WHITEFIELD,
BANGALORE - 560066.
…PETITIONER
Digitally signed
by VIJAYA P
Location: HIGH
COURT OF
KARNATAKA
(BY SRI. S. BUBNA SRISTI NIRMAL, ADVOCATE FOR
SRI. VENKATANARAYANA G.M., ADVOCATE)
AND:
1. THE SUPERINTENDENT OF CENTRAL TAX,
EAST DIVISION - 07,
BMTC BUS STAND,
HAL AIRPORT ROAD,
DOMMALURU,
BANGALORE - 560071.
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NC: 2026:KHC:15559
WP No. 39795 of 2025
HC-KAR
2. THE PRINCIPAL COMMISSIONER OF CENTRAL TAX,
BMTC BUS STAND,
HAL AIRPORT ROAD,
DOMMALURU,
BANGALORE - 560071.
…RESPONDENTS
(BY SRI. ARAVIND V. CHAVAN, ADVOCATE FOR R1 AND R2)
THIS W.P. IS FILED UNDER ARTICLES 226 AND 227 OF
THE CONSTITUTION OF INDIA PRAYING TO DIRECT THE R-1
TO ADJUDICATE AND SANCTION THE PETITIONER'S REFUND
CLAIMS PERTAINING TO THE PERIODS OCTOBER 2011-MARCH
2012, JULY 2012-SEPTEMBER 2012, AND JULY 2014-
SEPTEMBER 2014 FILED UNDER RULE 5 OF THE CENVAT
CREDIT RULES, 2004 READ WITH NOTIFICATION NO. 27/2012-
CE(NT) DTD. 18.06.2012 FORTHWITH AND WITHIN A TIME-
BOUND PERIOD AS MAY BE FIXED AND ETC.,
THIS PETITION, COMING ON FOR FRESH MATTERS, THIS
DAY, ORDER WAS MADE THEREIN AS UNDER:
CORAM: HON'BLE MR. JUSTICE S SUNIL DUTT YADAV
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NC: 2026:KHC:15559
WP No. 39795 of 2025
HC-KAR
ORAL ORDER
The petitioner has sought for issuance of writ of
mandamus to direct respondent No.1 to adjudicate and
sanction the petitioner's refund claim pertaining to the
period October-2011 to March-2012, July-2012 to
September-2012 and July-2014 to September-2014.
2. During the pendency of the present
proceedings, learned counsel appearing for the revenue
files a memo along with copy of the Order-in-Original and
submits that refund applications for the period which is
subject matter of the writ petition has been rejected by an
Order-in-Original dated 07.01.2026. In light of the same,
further adjudication in the present petition would not
arise, keeping open all contentions of the petitioner insofar
impugned Order-in-Original dated 07.01.2026.
3. Learned counsel for the petitioner submits that
the Court may take note of the submission that the Order-
in-Original was not communicated to the petitioner and
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NC: 2026:KHC:15559
WP No. 39795 of 2025
HC-KAR
has come to the knowledge of the petitioner only on this
day i.e., on 17.03.2026, when the copy is served by the
counsel for the revenue. The said aspect is taken note of.
4. Accordingly, petition is disposed of and liberty is
reserved to challenge by way of an appropriate proceeding
the Order-in-Original dated 07.01.2026. The aspect
regarding limitation to be taken note of while making note
of the observations made above. All contentions are kept
open.
Accordingly, petition is disposed of .
Sd/-
(S SUNIL DUTT YADAV)
JUDGE
MCR
NC: 2026:KHC:15559
WP No. 39795 of 2025
HC-KAR
IN THE HIGH COURT OF KARNATAKA AT BENGALURU
TH
DATED THIS THE 17 DAY OF MARCH, 2026
BEFORE
THE HON'BLE MR. JUSTICE S SUNIL DUTT YADAV
WRIT PETITION NO. 39795 OF 2025 (T-RES)
BETWEEN:
M/S. FIERY DIGITAL IMAGING INDIA PRIVATE
LIMITED,
(FORMERLY KNOWN AS ELECTRONICS FOR
IMAGING INDIA PRIVATE LIMITED),
(A PRIVATE LIMITED COMPANY, REPRESENTED
BY ITS ASSISTANT MANAGER,
ACCOUNTING APAC GL,
MR. ADITHYA HJ,
GROUND AND FIRST FLOOR, EBONY BLOCK,
PHASE II, KALYANI PLATINA,
EPIP ZONE, WHITEFIELD,
BANGALORE - 560066.
…PETITIONER
Digitally signed
by VIJAYA P
Location: HIGH
COURT OF
KARNATAKA
(BY SRI. S. BUBNA SRISTI NIRMAL, ADVOCATE FOR
SRI. VENKATANARAYANA G.M., ADVOCATE)
AND:
1. THE SUPERINTENDENT OF CENTRAL TAX,
EAST DIVISION - 07,
BMTC BUS STAND,
HAL AIRPORT ROAD,
DOMMALURU,
BANGALORE - 560071.
- 2 -
NC: 2026:KHC:15559
WP No. 39795 of 2025
HC-KAR
2. THE PRINCIPAL COMMISSIONER OF CENTRAL TAX,
BMTC BUS STAND,
HAL AIRPORT ROAD,
DOMMALURU,
BANGALORE - 560071.
…RESPONDENTS
(BY SRI. ARAVIND V. CHAVAN, ADVOCATE FOR R1 AND R2)
THIS W.P. IS FILED UNDER ARTICLES 226 AND 227 OF
THE CONSTITUTION OF INDIA PRAYING TO DIRECT THE R-1
TO ADJUDICATE AND SANCTION THE PETITIONER'S REFUND
CLAIMS PERTAINING TO THE PERIODS OCTOBER 2011-MARCH
2012, JULY 2012-SEPTEMBER 2012, AND JULY 2014-
SEPTEMBER 2014 FILED UNDER RULE 5 OF THE CENVAT
CREDIT RULES, 2004 READ WITH NOTIFICATION NO. 27/2012-
CE(NT) DTD. 18.06.2012 FORTHWITH AND WITHIN A TIME-
BOUND PERIOD AS MAY BE FIXED AND ETC.,
THIS PETITION, COMING ON FOR FRESH MATTERS, THIS
DAY, ORDER WAS MADE THEREIN AS UNDER:
CORAM: HON'BLE MR. JUSTICE S SUNIL DUTT YADAV
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NC: 2026:KHC:15559
WP No. 39795 of 2025
HC-KAR
ORAL ORDER
The petitioner has sought for issuance of writ of
mandamus to direct respondent No.1 to adjudicate and
sanction the petitioner's refund claim pertaining to the
period October-2011 to March-2012, July-2012 to
September-2012 and July-2014 to September-2014.
2. During the pendency of the present
proceedings, learned counsel appearing for the revenue
files a memo along with copy of the Order-in-Original and
submits that refund applications for the period which is
subject matter of the writ petition has been rejected by an
Order-in-Original dated 07.01.2026. In light of the same,
further adjudication in the present petition would not
arise, keeping open all contentions of the petitioner insofar
impugned Order-in-Original dated 07.01.2026.
3. Learned counsel for the petitioner submits that
the Court may take note of the submission that the Order-
in-Original was not communicated to the petitioner and
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NC: 2026:KHC:15559
WP No. 39795 of 2025
HC-KAR
has come to the knowledge of the petitioner only on this
day i.e., on 17.03.2026, when the copy is served by the
counsel for the revenue. The said aspect is taken note of.
4. Accordingly, petition is disposed of and liberty is
reserved to challenge by way of an appropriate proceeding
the Order-in-Original dated 07.01.2026. The aspect
regarding limitation to be taken note of while making note
of the observations made above. All contentions are kept
open.
Accordingly, petition is disposed of .
Sd/-
(S SUNIL DUTT YADAV)
JUDGE
MCR