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    <title>2025 (4) TMI 1234 - ALLAHABAD HIGH COURT</title>
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    <description>Where the statutory appellate tribunal had not yet been constituted and the dispute concerned penalty alone, no further pre-deposit was required under Section 112 because the provision was treated as directed to the tax amount in dispute, not penalty. Interim protection was also granted against enforcement of the penalty order, and release of the seized goods was permitted subject to compliance with Rule 140 of the CGST Rules, with the amount already deposited at the first appellate stage to be adjusted while fixing the security to be furnished.</description>
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      <description>Where the statutory appellate tribunal had not yet been constituted and the dispute concerned penalty alone, no further pre-deposit was required under Section 112 because the provision was treated as directed to the tax amount in dispute, not penalty. Interim protection was also granted against enforcement of the penalty order, and release of the seized goods was permitted subject to compliance with Rule 140 of the CGST Rules, with the amount already deposited at the first appellate stage to be adjusted while fixing the security to be furnished.</description>
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