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Validity of Assessment cum Penalty cum Interest Order - There is no denial of the fact that the petitioner is disputing correctness of the amounts that was arrived at by the 1st respondent. It is well settled under Article 226 of the Constitution of India, this Court cannot go into factual aspects. Further, there is no dispute that the petitioner has a right of Appeal under Section 107 of the CGST Act, 2017. - HC