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The HC stayed the impugned order invoking Section 73 of the CGST Act, 2017 for recovery of short paid tax due to discrepancy between GSTR-1 and GSTR-3B, holding that Section 73 allows recovery of tax not paid or short paid due to reasons other than fraud or willful misstatement, and the conclusions referring to Section 9 of CGST Act show liability created with reference to IGST and cess leviable.