ORDER

The petitioner has challenged the impugned Order-in-Original No. 01/2022 – GST, dated 23.03.2022 passed by the fifth respondent. By the impugned order, the fifth respondent has confirmed the demand proposed in the Show Cause Notice that preceded with the impugned order. Operative portion of the impugned order reads as under:-

“ORDER

i. I confirm the demand of an amount of Rs. 22,50,53,102/- (Rupees Twenty Two Crore Fifty Lakh Fifty Three Thousand One Hundred and Two only) (IGST: Rs.22,50,53,102/-) made on M/s. Shobikaa Impex Private Limited, Karur towards the ineligible refund of IGST paid on exports availed by them during the period from January, 2019 to September, 2020, made under Section 74(1) of Central Goods and Services Act, 2017 read with the Section 20 of the IGST Act, 2017 along with the corresponding provisions of the SGST Act and I determine the same under Section 74(9) of the CGST Act, 2017 read with read wit