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    <description>Interim protection was granted against coercive recovery of tax and penalty demands where the challenge concerned alleged non-service of the impugned order and rejection of the appeal as time-barred. The restraint was made conditional on compliance with the statutory pre-deposit and security framework under the Uttar Pradesh GST law: deposit of the tax amount and 50% of the penalty, with security for the balance penalty after adjusting amounts already paid. The operative effect was that recovery action remained stayed only so long as the prescribed deposit and security requirements were satisfied.</description>
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