JUDGMENT :

(Manish Choudhury, J.) :

The petitioner has instituted the instant writ petition under Article 226 of the Constitution of India to assail the original proceedings which was initiated by a Demand-cum-Show Cause Notice bearing no. C.No. V[15]75/ADJ/CGST-HQRS/GHY/ST/2021/1421 dated 26.04.2021 resulting into an Order-in-Original no. 61/Addl. Commr./ST/GHY/2021-22 dated 01.03.2022 passed by the Additional Commissioner, O/o the Principal Commissioner, GST & Central Excise Commissionerate, Guwahati [the respondent no. 3] and the appeal proceedings which emanated from the appeal preferred by the petitioner as appellant against the Order-in-Original dated 01.03.2022 culminating in an Order-in-Appeal bearing no. 528/GHY[A]/COM/ST/GHY/ 2023 dated 21.09.2023 of the Commissioner [Appeals], CGST, Central Excise & Customs, Guwahati [the respondent no. 2].

1.1. The Order-in-Original no. 61/Addl. Commr./ST/GHY/2021-22 [‘the Order-in-Original’, for short] dated 01.03.2022 passed by the respondent no. 3 [hereinafter referred to as ‘the Adjudicating Authority’, for easy reference] was against the interests of the petitioner. By the Order-in-Appeal bearing no. 528/GHY[A]/COM/ST/GHY/2023 [‘the