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It is directed that respondents shall not take any coercive steps against petitioner pursuant to the impugned letter directing petitioner to deposit balance interest till the next date of hearing.

Section 50 of the CGST Act, 2017 — Interest –– The petitioner challenged recovery letter dated 25.03.2022 directing him to deposit balance interest of Rs. 20,15,20,625/- till 28th of March, 2022. Any recovery under the Act can be made only after determining amount of liability upon the petitioner. No such notice, as required under Sections 73 or 74 of Act, has been issued by respondent-department The respondent counsel submitted that he may be granted three weeks' time to file detailed reply.

Held that:- The Hon’ble High Court directed the respondents to not to take any coercive steps against petitioner pursuant to the impugned letter dated 25.03.2022 till the next date of hearing. List the matter immediately after three weeks.

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