JUDGMENT

[Physical Court hearing/ Hybrid hearing (as per request)]

TABLE OF CONTENTS

Rajiv Shakdher, J.

Preface:

1. The sole question which arises for our consideration is: whether the cumulative sum of Rs.1,80,10,000/- deposited on behalf of the petitioner- concern, during search proceedings carried out between 16.02.2022 and 17.02.2022, was a voluntary act or not.

2. The petitioner claims, that the aforementioned amount was deposited in four (4) tranches, between 01:28 A.M. and 07:03 A.M. on 17.02.2022.

3. It is the petitioner's case, that the search commenced at about 03:30 PM on 16.02.2022 and ended at 09:30 AM on 17.02.2022.

4. Respondents no. 1 and 2 ["official respondents"]/revenue, however, contend to the contrary.

4.1. It is the official respondents/revenue's broad stand, that the aforementioned amount was deposited against challan(s) submitted in the prescribed form i.e., Form GST DRC-03, each of which is dated 17.02.2022.

5. The official respondents/revenue, thus, take the position, that the allegation of coercion is an afterthought, which was raised only on 25.05.2022 after su