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Issues: Whether the petitioner should be permitted to pursue the statutory appellate remedy against the order-in-original and Form GST DRC-07 despite delay.
Analysis: No merits of the tax demand or the challenged proceedings were adjudicated, since the petitioner elected to avail the appellate remedy. Liberty was granted to file an appeal with statutory pre-deposit and an application for condonation of delay; the appellate authority was directed to consider delay and, if satisfied, determine the appeal on merits in accordance with law.
Outcome: The writ petition was disposed of by granting liberty to file a statutory appeal within two weeks; coercive action pursuant to the garnishee notice was restrained during that period.