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Issues: Whether the petitioner's representation seeking recognition of the amount already deposited as pre-deposit for filing the statutory appeals through the GST portal was required to be considered by the Appellate Authority, and whether the authority should act in accordance with the portal instructions and the Supreme Court decision relied upon.
Analysis: The petitioner had already complied with the earlier judicial direction to deposit 10% of the disputed tax, and the subsequent assessment orders were passed after de novo adjudication. The grievance was that, because of changes in the GST portal architecture and the appeal manual, the deposited amount was not being treated as the requisite pre-deposit for the appeals, and approval from the competent authority was being insisted upon. In that situation, the Court directed the Appellate Authority to consider the representation in the light of the appeal manual then in force and to take into account the Supreme Court decision referred to by the petitioner.
Conclusion: The representation was directed to be considered by the Appellate Authority, and the petitioner obtained a partial procedural relief.