Penalty under pre-commencement CGST provisions remains unresolved as interim protection against coercive action was granted.

The applicability of penalty under Section 122(1A) of the CGST Act to transactions alleged to have occurred before its commencement remained unresolved at this stage. The Delhi HC noted the challenge to the underlying order and the reliance on a similar decision of another High Court, but did not finally determine the merits. Notice was issued, a counter affidavit was called for, and interim protection against coercive action was granted pending further hearing.

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Issues: Whether penalty under Section 122(1A) of the Central Goods and Services Tax Act, 2017 could be applied to transactions alleged to have occurred prior to its commencement, and whether interim protection against coercive action was warranted pending further hearing.

Analysis: The question of the commencement and applicability of the penalty provision was noticed, along with the pending challenge concerning the underlying order and the reliance placed on a similar decision of another High Court. The matter was not finally adjudicated at this stage; instead, notice was issued, a counter affidavit was called for, and interim protection was considered appropriate.

Outcome: No final ruling was rendered on the applicability of Section 122(1A) of the Central Goods and Services Tax Act, 2017. Notice was issued and interim restraint on coercive measures was granted pending further consideration.

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