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The HC held that the impugned penalty levy under s.125, GST Act, was vitiated for denial of audi alteram partem; noting that an appeal had been dismissed as time-barred, the court nevertheless quashed the orders dated 18.12.2024 and 28.07.2025 for failure to afford an opportunity of hearing. The petition is allowed by way of remand: the matter is returned to the competent authority to rehear and pass a fresh adjudicatory order in accordance with law and principles of natural justice. Directions ensure fresh proceedings conform to statutory limitation rules and afford the Applicant a full opportunity to be heard before any fresh penalty is imposed.