JUDGMENT :

Aniruddha Roy, J.

Facts:

1. The petitioner as a consignor claims to have supplied and transported Dried Areca Nuts (hereinafter, the nuts) for a quantity of 34,650 kgs.pursuant to the order placed by one M/s. Barman Tradecomm at New Delhi (hereinafter, the consignee).

2. During the transit the truck, through which the goods were transported, was intercepted by the CGST Authority and the consignment and the conveyance had been detained.

3. The revenue authority had issued a show-cause notice dated March 30, 2026, annexure P5 at page 33 to the writ petition under Section 129(3) of 2017 Act read with Section 20 of IGST Act, 2017.

4. Petitioner has submitted its reply dated April 2, 2026, Annexure P6 at page 40 to the writ petition.

5. The revenue authority then passed its order dated April 6, 2026 at page 46 to the writ petition and then issued the demand dated April 6, 2026, Annexure P7 at page 44 to the writ petition for a total sum of Rs.51,87,380/- for 35,530 kgs of nuts and additionally on account of conveyance a sum of Rs.2,00,000/-.

6. Page 50 of the writ petition shows that, the demand in terms of Section129(1)(a) of the 2017 Act is for a sum of Rs.5,18,738/- and the demand