JUDGEMENT

SANJEEV SACHDEVA, J. (ORAL) W.P.(C) 4149/2024 Page 2 of 5

1. Petitioner impugns order dated 30.12.2023, whereby the impugned Show Cause Notice dated 22.09.2023, proposing a demand of Rs. 1,96,12,996.10 against the Petitioner has been disposed of and a demand including penalty has been raised against the Petitioner. The order has been passed under Section 73 of the Central Goods and Services Tax Act, 2017 (hereinafter referred to as the Act).

2. Learned counsel for Petitioner submits that Petitioner was served with a Reminder Notice dated 28.11.2023 asking him to furnish a reply to the Show Cause Notice dated 22.09.2023. He further submits that the Petitioner filed a detailed reply dated 29.11.2023 and an additional reply dated 07.12.2023 to the Show Cause Notice. However, the impugned order dated 30.12.2023 does not take into consideration the replies submitted by the Petitioner and is a cryptic order.

3. Perusal of the Show Cause Notice shows that the Department has given separate headings i.e., excess claim Input Ta