The High Court disposed of the writ petition, directing the petitioner to deposit the required pre-deposit amount and file an appeal before the GSTAT within the specified timeline.

The Tribunal observed that revenue has compared the figures reflected in the ST-3 returns and figures reflected in Form 26AS statement and raised the demand without further examining the reasons for the difference in the two statements.

In this case, the Complaint satisfies the legal requirement by naming all accused Directors/officers, with specific averments that they were all “in charge of day-to-day affairs and responsible for the decisions” of the Company.