Maintainability of appeal requiring pre-deposit of Rs.2,00,00,000; interim protection for one week upon receipt and listing follows

Maintainability of the challenge is conditioned on compliance with a specified pre-deposit of Rs. 2,00,00,000 to the designated revenue account, and the requirement to produce the deposit receipt in the Registry within ten days; failure to comply results in dismissal for non-prosecution. Upon production of the receipt within one week, no coercive action shall be taken and interim protection continues until final disposal. The matter is listed for further hearing on the specified date. The operative consequences are financial pre-deposit, continuance of interim protection upon proof of deposit, and dismissal for non-compliance.

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Issues involved:
1. Assessment completion status for the relevant period under the Central Goods and Services Tax Act, 2017.
2. Applicability of Section 132 of the Act.
3. Petitioner's right to appeal and deposit requirements.
4. Notice issuance and deposit conditions.
5. Protection against coercive action.

Analysis:
1. The judgment addresses the issue of assessment completion for the relevant period under the Central Goods and Services Tax Act, 2017. The petitioner's counsel highlights that the Department has not completed the assessment yet, indicating that invoking Section 132 of the Act is premature in this scenario.

2. The judgment discusses the applicability of Section 132 of the Central Goods and Services Tax Act, 2017. The petitioner's counsel argues that since the assessment is pending, there is no basis for invoking Section 132 at this stage.

3. The judgment delves into the petitioner's right to appeal and the deposit requirements associated with it. The counsel asserts that even if the alleged liability of Rs. 19 crores is accepted, the petitioner can file an appeal after the assessment order is passed, subject to depositing 10% of the disputed liability. The petitioner expresses willingness to deposit Rs. 2,00,00,000 within a week.

4. The judgment issues notice on the condition that the petitioner deposits Rs. 2,00,00,000 to the credit of the Commissioner of GST & Central Excise, Salem, Tamil Nadu, and produces the receipt in the Registry within ten days. Failure to comply will result in the dismissal of the special leave petition for non-prosecution.

5. The judgment provides protection against coercive action for one week, stating that no such action should be taken against the petitioner in connection with the alleged offense during this period. The interim protection continues upon the production of the receipt of deposit made with the Department within one week, until the disposal of the Special Leave Petition.

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