Appeal — Assessment for the relevant period has not been completed by the Department so far. In which case, invoking Section 132 of the CGST Act does not arise, even if, the alleged liability of Rs.19 crores as is assumed by the Department is accepted, it is open to the petitioner to file appeal after the assessment order is passed; and as per the statutory stipulation, such appeal could be filed upon deposit of only 10% of the disputed liability. The petitioner is willing to deposit within one week. For a period of one week, no coercive action be taken against the petitioner in connection with the alleged offence. — C. Pradeep Vs. The Commissioner of GST And Central Excise Selam & Anr. [2019] 15 TAXLOK.COM 125 (SC)