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Petitioner alleges compliance with pre-deposit obligations at two appellate stages and seeks relief from recovery; court directed petitioner to make representation to GST authorities proving payment and allowed authorities to verify and call for clarifications. Any sum recovered in excess of the cumulative deposits required at the two appellate stages must be refunded. Court did not determine merits and left substantive decision to the GST authorities, who may examine evidence and take an informed decision on refund and stay-related consequences.
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