Section 50 of the CGST Act, 2017 — Interest —- The petitioner challenged order dated 05.01.2022 and to direct the respondents to compute and accept the interest liability based on the amount available / credited in the Electronic Cash Ledger. In respect of the Assessment Year 2017-18, to 2020-21, it is the case of the Revenue that, the monthly tax due payable by the petitioner in most of the months paid belatedly as otherwise, the tax due of every month should have been paid on or before 20th of succeeding month. The counsel for the petitioner submitted that, under Section 49 , where under explanation ''a", the date of credit to the account of the Government in the authorised Bank shall be deemed to be the date of deposit in the electronic cash ledger. If that being so, whenever the petitioner paid the tax by way of credit in the account of the Government, that date shall be taken into account as the date of payment of tax in the electronic cash ledger. Pursuant to the impugned demand, the Bank accounts of the petitioner has been freezed, therefore the petitioner's business has been crippled. The court observed that under Section 107 of the Act, since the Appeal remedy is available, the petitioner can very well agitate the issue by way of Appeal. Since these orders impugned was passed only on 05.01.2022, the petitioner is having limitation to file an Appeal.

Held that:- The Hon’ble High Court dismissed petitions and granted liberty to the petitioner to file appeal against the impugned demand to the Appellate Authority within the limitation period.