JUDGMENT

Vibhu Bakhru, J.

Introduction

1. The petitioner has filed the present petition impugning a show cause notice dated 28.02.2022 (hereafter `the impugned show cause notice') and an order dated 30.03.2022 (hereafter `the impugned order') passed under Section 74 of the Central Goods and Services Tax Act, 2017 (hereafter `the CGST Act'), pursuant to the impugned show cause notice. In terms of the impugned order, the Adjudicating Authority had raised a demand of Rs.27,88,200/- for the Financial Year 2020-21 and had called upon the petitioner to pay the same by 30.04.2022. In addition, the petitioner also impugns the instructions dated 08.03.2022 issued by the Department of Trade & Taxes (Policy Branch), Government of NCT of New Delhi (hereafter `the impugned instructions').

2. The Input Tax Credit (hereafter `ITC') available in the petitioner's Electronic Credit Ledger (hereafter `ECL') was blocked on 26.11.2020 under Rule 86A of the Central Goods & Services Tax Rules, 2017 (hereafter `the Rules'). The respondents did not unblock the same immediately on the expiry of the period of one year. The respondents did so on 30.03.2022, but appropriated the blocked ITC against a tax deman