JUDGMENT :

Devashis Baruah, J.

Heard Mr. A. K. Purkasthya, the learned counsel appearing on behalf of the petitioner. Mr. S.C. keyal, the learned Standing Counsel appears on behalf of the respondent Nos. 1,2,3 & 4.

2. The instant writ petition has been filed challenging the Order-In-Original No.215/AC/DIV-1/CGST/2023-2024 dated 26.03.2024 whereby the Assistant Commissioner, GST & Central Exercise, Headquarters Anti-Evasion Unit, CGST, Guwahati had passed an order thereby confirming the demand of service tax amounting to Rs. 16,04,738/-on the services rendered during FY 2016-17 in terms with the proviso to sub section (1) of Section 73 of the Finance Act, 1994. In addition to that the petitioner was also saddled with the liability of interest and penalty as mentioned in the impugned order.

3. This Court further takes note of that the said order is appealable in terms with Section 107 of the CGST Act, 2017 to the Commissioner (Appeals), Customs, CGST and Central Excise (NER), GST Bhawan that to within 60 days from the date of the said communication.

4. The case of the petitioner as set out to challenge the said impugned order before this Court is that the petitioner on account of personal