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Issues: Whether the respondents should be restrained from taking coercive action against the petitioner pending consideration of the notice, in view of the claimed allocation of jurisdiction and administrative control under the GST arrangement.
Analysis: The petitioner asserted that the impugned notice and consequential order were beyond the competence of the State authorities because jurisdiction had been allocated to the Centre under the cited GST provisions, the GST Council guidelines, and the relevant circular and order governing division of the taxpayer base. On that basis, interim protection was sought against further action pursuant to the show cause notice and final order.
Conclusion: No coercive action shall be taken against the petitioner pursuant to the show cause notice and the final order until further proceedings.