aggrieved by the order dated 24th December, 2024, the
petitioners intend to file an appeal before the Appellate
Tribunal. Since, the Appellate Tribunal has not been made
operational, the petitioners, had in terms of Section 112(8)
of the said Act read with Section 143 of the Finance (No.2)
Act 2024, made the additional mandatory pre-deposit of
10 per cent of the disputed amount of tax, constituting
Rs.17,658/- for CGST as also Rs.17,658/- for SGST.
Accordingly having regard to the circular dated 11th July,
2024 and the provisions contained in Section 112(9) of the
said Act, the petitioners had requested the respondents
not to proceed with the recovery proceeding.
5. Ms. Agarwal, learned advocate appearing on behalf
of the petitioners by placing before this Court a printout of
the electronic liability ledger for the tax period 1st
January, 2025 to 11th January, 2025, would submit that
the respondents have already in the most illegal and
arbitrary manner recovered from the petitioners, partly
from the cash ledger and partly from credit ledger an
amount of Rs.342/- and Rs.49988/- respectively
aggregating to Rs.50,330/-. She would submit that in the
facts noted hereinabove, the aforesaid recovery is bad in
law and cannot be sustained.