TaxTMI 
TaxTMI 
2026 (5) TMI 1436
X X X X Extracts X X X X
X X X X Extracts X X X X
....d that this Hon'ble Court may graciously be pleased to issue Rule Nisi, in the nature of writ of MANDAMUS and/or any other appropriate writ/writs, direction/directions and order/orders, calling upon the Opp. Parties to show cause as to why the Notice vide DRC-13 dt.09.03.2026, Letter No.968/ dt.09.03.2026 and Letter No. 2769/dt.24.03.2026 issued by the O.P. No.4 vide Annexure-6, 7 & 9 respectively shall not be quashed; AND Further be pleased to direct the O.Ps. to consider the grievance of the petitioner submitted vide Annexures-8 & 11, by allowing some time to make the balance payment towards GST liability, being admitted by the petitioner, on such suitable equal installments; AND If the Opp. Parties fai....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ly), no heed is paid by revoking the attachment order. Since the attachment order has been issued under Section 79 of the GST Act, the petitioner is unable to discharge its liability under the OGST Act. 4.2. He further submitted that this writ petition in the nature of mercy petition has been filed to enable the petitioner to deposit the demanded amount in installments. 5. Sri Sunil Mishra, learned Standing Counsel appearing for the CT & GST Organization vehemently objected for grant of relief claimed by the petitioner. He submitted that there is no provision in the statute to allow the petitioner to discharge tax liability, as admitted, in installments. 5.1. Referring to the Date-Chart, Sri Sunil Mishra, learned Standing Counsel s....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... the petitioner to make payment of Rs.2,49,61,525.02P. to the Government forthwith or upon the money becoming due or being held. Such notice is subject matter in the writ petition for consideration. 7.2. When the matter was taken up on 18th May, 2026, the following order was passed on the assurance of the counsel for the petitioner: "1. The petitioner has challenged several orders of attachment issued by the GST Authority on the premise of non-payment of the dues pertaining to the GST within the time stipulated in several notices issued in the prescribed form. 2. Though there does not appear to be any dispute on the liability to pay the tax so demanded or the amount for which the attachment order is issued, the counsel ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....unts of the Petitioner-Company in the Bank of Baroda, Nayapali Branch, Bhubaneswar and Odisha Grameen Bank, Head Office Gandamunda, Bhubaneswar, amounting to Rs. 2,47,51,021/- (Two Crores Forty Seven Lakhs Fifty One Thousand Twenty One Rupees), the admitted tax, within a period of two months, from the date of revocation and/or withdrawal of the said attachments and consequential recovery process." 7.4. In view of such Affidavit of Undertaking dated 20.05.2026 furnished by the Managing Director and the Director of the Petitioner-Company, in the interest of justice, it is apposite to dispose of the writ petition with the following directions/observations: i) The petitioner shall deposit fifty percent of the amount of Rs. 2,47,51,0....