HIGH COURT OF JUDICATURE AT ALLAHABAD WRIT TAX No. - 3409 of 2025 Court No. - 3 HON'BLE SAUMITRA DAYAL SINGH, J. HON'BLE INDRAJEET SHUKLA, J. 1. Having heard Mr. Suyash Agarwal, learned counsel for the petitioner and Mr. Arvind Mishra, learned counsel for the revenue, we do not find this a fit case to offer interference under Article 226 of the Constitution of India. The petitioner was first issued a show cause notice dated 07.11.2024 under Section 74 of the U.P.G.S.T. Act, 2017 seeking finalization of demand at Rs. 24,880,88,467.80. The petitioner submitted it's reply thereto on 01.12.2024. The matter remained pending. On 04.02.2025, the Adjudicating Authority issued a reminder notice dated 04.02.2025 fixing the date for reply for 11.02.2025 and the date for personal hearing for 17.02.2025. In that notice, demand proposed to be finalized was revised to Rs. 38,35,04,310.56. 2. While it may merit consideration that such enhancement of the proposed demand may not be permissible through a reminder notice and for that a fresh notice may be required, that issue being raised may remain open to the petitioner to contest in regular proceedings of appeal. We are disinclined to offer any interference at this stage for the reason that it is an admitted position of fact that the petitioner chose not to furnish any reply to the above "reminder notice" dated 04.02.2025 inasmuch as neither it filed any further reply on the date fixed for that purpose i.e. 11.02.2025 nor it appeared before the Adjudicating Authority on 17.02.2025. 3. At this stage, we note, the ground being raised in the present proceeding would remain available to the petitioner in the statutory Versus Counsel for Petitioner(s) : Suyash Agarwal Counsel for Respondent(s) : C.S.C. S A Products Part Of Premises .....Petitioner(s) Deputy Commissioner, State Tax Sector -06, Kanpur And Another .....Respondent(s) proceeding of appeal that may be instituted. 4. Insofar as the present petition was filed within the statutory period of limitation to file an appeal, it is provided, if such appeal is filed by 31.10.2025, the same may be entertained on merits without raising any objection as to limitation. 5. Accordingly, the present petition stands disposed of. October 6, 2025 Prakhar WTAX No. 3409 of 2025 2 (Indrajeet Shukla,J.) (Saumitra Dayal Singh,J.) Digitally signed by :- PRAKHAR SRIVASTAVA High Court of Judicature at Allahabad