Protection from coercive recovery cannot be made conditional on further deposit after 30% disputed tax is already paid under GST appeal rules.

After payment of 30% of the disputed tax, no further deposit could validly be insisted upon as a condition for protection from coercive recovery under section 112 of the West Bengal GST Act. The court treated the earlier 10% appellate deposit and the additional 20% paid under writ directions as sufficient compliance with the statutory requirement, so the further 20% condition was unsustainable and protection from coercive recovery was directed to continue.

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Issues: Whether, after payment of 30% of the disputed tax, any further condition could be imposed for protection from coercive recovery action under section 112 of the West Bengal Goods and Services Tax Act, 2017.

Analysis: The appellants had already deposited 10% at the appellate stage and a further 20% pursuant to the writ court's direction. The resulting payment of 30% was treated as sufficient compliance with the requirement under section 112. In that situation, no further deposit could validly be insisted upon as a condition for protection against coercive recovery.

Conclusion: The additional condition requiring payment of a further 20% of the disputed tax was not sustainable, and protection from coercive recovery was directed to continue.

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