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HC dismissed the writ petition, directing the petitioner to pursue appellate remedies under Section 107 of CGST Act. The court held that factual issues regarding penalty imposition, transaction benefits, and financial year challenges should be adjudicated through the appellate process. The petitioner retains the right to contest the CGST Department's penalty under Section 122(1A) through appropriate appellate channels, with the appellate authority deemed most suitable to comprehensively examine the matter.
HC dismissed the writ petition, directing the petitioner to pursue appellate remedies under Section 107 of CGST Act. The court held that factual issues regarding penalty imposition, transaction benefits, and financial year challenges should be adjudicated through the appellate process. The petitioner retains the right to contest the CGST Department's penalty under Section 122(1A) through appropriate appellate channels, with the appellate authority deemed most suitable to comprehensively examine the matter.
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