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Issues: Whether the petitioner was entitled to interim protection against coercive action pursuant to the impugned refund-related instructions and show cause notice.
Analysis: The petition questioned instructions directing denial of refund of unutilized input tax credit on export and recovery of refunds already granted, as well as the consequent show cause notice. Pending consideration of the challenge, the Court found it appropriate to protect the petitioner from coercive steps while permitting the proceedings on the show cause notice to continue only to the stage of reply, without giving effect to any consequential order.
Conclusion: Interim protection was granted in favour of the petitioner against further action pursuant to the impugned instructions, and the consequential order on the show cause notice was stayed.