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In a challenge concerning GST proceedings for delayed return filing, the court noted that no late fee under s.47 had been imposed, and held that if the confirmed tax demand had already been recovered and paid, no further pre-deposit would be required for the de novo proceedings arising from the impugned order dated 24.08.2024, and the assessee must file a reply to Form GST DRC-01 with supporting documents treating the impugned orders as an addendum to the show cause notice. The challenge to the assessment order was dismissed, while the remaining impugned orders were remanded subject to deposit of 50% of the disputed tax. - HC