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The Department did not answer the questions posed by the Court, i.e., in what manner is three times the monthly SGST tax taken to be the principal and 100% penalty imposed. At this position, It is for the petitioner to file an application seeking review of the order and not preferring the SLP.

Section 62 of the CGST Act, 2017— Assessment Orders –—-- The court observed that the impugned order shows that the Counsel for the Department did not answer the questions posed by the Court, i.e., in what manner is three times the monthly SGST tax taken to be the principal and 100% penalty imposed. The Counsel contended that there is an explanation for the same but the matter was disposed of on the first date itself and possibly the Counsel could not assist the Court. The court observed that it is for the petitioner to file an application seeking review of the order and not preferring the SLP.

Held that:- The Hon’ble Court dismissed the special leave petition with the aforesaid liberty.

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