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    Statutory GST appellate limitation cannot ordinarily be bypassed through writ jurisdiction after it has expired following unexplained delay.
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A single adjudication order creating tax and penalty liability...

Composite demand notices cannot force multiple appeals or extra pre-deposit for penalty arising from one adjudication order.

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GST April 18, 2026 Case Laws HC
A single adjudication order creating tax and penalty liability cannot be split through separate DRC-07 notices so as to force multiple appeals or an additional pre-deposit toward penalty. The statutory appeal mechanism is satisfied by one appeal against the composite order on deposit of 10% of the disputed tax demand, without any further deposit at that stage for the penalty component. The Court permitted withdrawal of the two notices and issuance of a fresh composite DRC-07, and clarified that limitation for appeal would run from service of the fresh notice, with no further recovery pending compliance.

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Acts Income Tax