Neutral Citation No. - 2025:AHC:141048-DB Court No. - 3 Case :- WRIT TAX No. - 3755 of 2025 Petitioner :- M/S Rana Pratap Singh Respondent :- Union Of India And 2 Others Counsel for Petitioner :- Birendra Singh,Swati Singh Counsel for Respondent :- C.S.C.,Krishna Agarawal Hon'ble Shekhar B. Saraf,J. Hon'ble Praveen Kumar Giri,J. 1. Heard learned counsel appearing on behalf of the petitioner, Sri Krishna Agrawal, learned counsel appearing on behalf of the respondent No.1 and Sri Ankur Agarwal, learned Standing Counsel appearing on behalf of the State respondents. 2. This is a writ petition under Article 226 of the Constitution of India wherein the writ petitioner has sought for the following substantial relief: "Issue a writ, order or direction in the nature of Certiorari quashing the order/notice dated 06.05.2025 passed by the Assistant Commissioner, State Tax, Khand 3, Bhadohi imposing penalty total of Rs.23231003/- (Two Crore Thirty Two Lakh Thirty One Thousand and Three Rupees only) which includes GST on Royalty, GST on Mineral Sales, GST on Poclain Machine used on Rental Basis, Penalty on the GST and interest on the penalty." 3. Upon hearing counsel appearing on behalf of the parties and perusing the documents, it appears that the petitioner had filed its reply and the authorities have allegedly rejected the reply of the petitioner without going into the same. In our view, whether the reply of the petitioner has been considered correctly or not is a subject matter which can be taken up in appeal under Section 107 of Uttar Pradesh Goods and Services Tax Act, 2017. 4. Since the limitation of filing the appeal is still not over, the petitioner is directed to file the appeal. Upon filing of the appeal by the petitioner, the appellate authority is directed to grant an opportunity of hearing to the petitioner, and thereafter, pass a reasoned order in accordance with law in an expeditious manner. 5. With the aforesaid directions, the writ petition is disposed of. Order Date :- 19.8.2025 Kuldeep (Praveen Kumar Giri, J.) (Shekhar B. Saraf, J.) Digitally signed by :- KULDEEP SINGH High Court of Judicature at Allahabad