Section 50 of the CGST Act, 2017 — Interest –– The counsel for the petitioner submitted that since the tax due has already been paid, therefore, the notice dated 25.03.2022 issued under proviso to sub-section (1) of Section 50 even without issuing SCN as required under Section 73 not sustainable. The counsel for the respondents submitted that the date of filing of return would be the acknowledgment of receipt of tax and not the payment of tax itself and since the return has been filed after a due date, therefore, there is no infirmity in issuance of alleged notice demanding interest on delayed payment of tax. The court considering the contentions, inclined to stay the effect and operation of impugned notice.

Held that:- The Hon’ble High Court directed that the effect and operation of the impugned notice dated 25.03.2022  shall remain stayed till the next date of hearing. Posted the matter after summer vacation for consideration.