Show Cause Notice ----------The petitioner challenged the appellate order dated 26.10.2021 and the order dated 04.06.2021. The counsel for the petitioner submitted that before filing its annual return, certain discrepancy and difference was caused due to re-conciliation and timing of the realization of the bills which was spread over two financial years i.e. 2017-18 and 2018-19. The petitioner was issued notice, which was duly replied that certain payments which were related to financial year 2017-18 were received in the financial year 2018-19. The petitioner has already deposited the tax and by not accepting the submissions and explanations, it amounts to double taxation which is not permissible. The petitioner has a remedy of filing an appeal before the GST Tribunal in terms of Section 112 of the Act, however, till date the Tribunal has yet not been constituted. The Court observed that the matter requires consideration.

Held that:- The Hon’ble High Court listed the matter on 28.02.2022. As an interim measure, directed that no coercive measure shall be taken against the petitioner in case if he furnishes a valuable security to the tune of Rs. 32,00,000/- with the Assessing Officer within a period of two weeks.