[Judgment of the Court was made by N.SATHISH KUMAR, J.)

Challenging the order of the learned Single Judge directing the appellant to deposit 25% of the disputed tax amounting to Rs.5,23,09,082/- within a period of six months from the date of receipt of a copy of the order, the present writ appeal has been filed.

2. The appellant had filed the writ petition challenging the impugned order in Form GST DRC-07 bearing Reference No. ZD330824285003J dated 30.08.2024, whereby the first respondent demanded tax of Rs.2,61,54,541/- each under the CGST Act and the SGST Act.

3. The learned counsel appearing for the appellant submitted that, upon scrutiny of the statutory monthly returns filed for the financial year 2019–2020, the first respondent issued a show cause notice dated 27.05.2024. The said notice was uploaded on the GST portal and was not served through any other mode. The allegations in the show cause notice pertain to: (i) Reconciliation of E-way Bill turnover with GSTR-01;(ii) Reconciliation of t