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Excess ITC was denied under Section 16(4) due to non-reconciliation between GSTR-3B and related disclosures, and the taxpayer had not responded to the show cause notice. The Court found a prima facie overlap in the demand confirmed in the impugned order and, to prevent unjust duplication while ensuring revenue protection, directed the taxpayer to deposit 25% of the disputed tax and file a reply within 30 days. Upon such compliance, the adjudicating authority was directed to pass a fresh order on merits within three months and the bank account attachment would stand vacated; the petition was disposed. - HC
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