SAVVY FOODS (INDIA) Vs. STATE OF KARNATAKA

JUDGEMENT

(1.) THESE forty -eight (48) appeals are filed under Section 63 of the Karnataka Value Added Tax Act, 2003 (hereinafter referred to as 'the Act') contesting the common appeal orders dated 19th December, 2012 in Case Nos. VAT.AP. 212 to 259/2011 -12 bearing C.A.S. Order No. 26279894 A.P.P. passed under Section 62(6) of the Act by the Joint Commissioner of Commercial Taxes (Appeals -2), Bangalore (hereinafter referred to as 'First Appellate Authority' or for short as 'F.A.A.') for the tax periods of April 2006 to March 2010 respectively. By the said impugned appellate order, the F.A.A. has upheld the reassessment orders dated 28th February, 2011 passed under Section 39(1) of the Act, by the Deputy Commissioner of Commercial Taxes (Enforcement -II), South Zone, Bangalore for the 48 tax periods of April 2006 to March 2010 (hereinafter referred to as 'Assessing Authority' or for short as 'A.A.'). The A.A. has passed common reassessment order but within the same, the separate orders have been concluded for all the forty -eight impugned tax periods from April 2006 to March 2010. The appellant has prayed to set aside the orders of the F.A.A. and to accept the declared turnovers and tax liability and further prayer has been made to cancel the disputed tax, interest and penalty levied. This case has been heard along with appeals of M/s. Pioneer Trading bearing S.T.A. Nos. 630 to 677 of 2013 which is transferred from another Bench.

(2.) BRIEF facts:

(3.) (i) The learned Counsel has relied on the following decisions: