Section 174 of the CGST Act, 2017 --- Transitional Provisions —- The petitioner challenged letters dated 29.07.2019 and 30.07.2019 calling upon the petitioner to make service tax payments along with applicable interest and penalty for the period of FY 2014-15 to 2017-18 (April-June) and SCN dated 18.10.2019 proposing imposition of the levies. The petitioner contended that the proceedings initiated by issuance of the impugned SCN and the impugned letters are not saved under Section 174 of the Act. The court observed that a plain reading of Section 174(2) states that the amendment to the Finance Act would not affect the operation of the amended Act (Finance Act) and it would also not affect any obligation or liability ‘accrued’ or ‘incurred’ under the Finance Act.

Held that:- The Hon’ble Court dismissed the petition.