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This court is of the view that a little leeway should be given to the petitioner. Accordingly, the petitioner is directed to deposit the amount of tax in installment.

Section 83 of the CGST Act, 2017— Provisional Attachment of the Bank Accounts -- The petitioner challenged the order of attaching the bank accounts under Section 83. The petitioner counsel submitted that the petitioner has been remiss in not completely complying with the directions, contained in order dated 05.04.2021 because of ongoing Coronavirus, the petitioner is facing difficulties in collecting dues from its own debtors. The petitioner, insofar as the condition contained in paragraph 4 (i), of order dated 05.04.2021, is concerned, which required the petitioner to remit a further amount of Rs. 5,00,00,000, on or before 20.05.2021, the petitioner has deposited Rs. 2,00,00,000. The court in its direction dated 24.05.2021 observed that there is a Coronavirus pandemic raging in the country, they are inclined to give a short accommodation to place the petitioner’s difficulties on record, by way of an affidavit. The petitioner agreed to deposit Rs. 25,00,000. The court observed that the petitioner has deposited Rs. 2,25,00,000/-. Held that:-The Hon’ble High Court directed the petitioner to deposit Rs. 2,75,00,000/- on or before 05.07.2021. Listed the matter on 06.07.2021.
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