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Where the statutory appeal under s. 107 of the GST enactments, 2017 had become time-barred and the assessee invoked writ jurisdiction belatedly, the Court held that, consistent with prior similar orders, the interests of revenue and the assessee could be balanced by setting aside the impugned order and directing a de novo decision on merits subject to a protective pre-deposit. The matter was remitted to the proper authority to pass a fresh order on merits, conditional upon deposit of 25% of the disputed tax in cash through the electronic cash ledger within 30 days, and the writ was disposed accordingly - HC