HIGH COURT OF JUDICATURE AT ALLAHABAD CIVIL MISC REVIEW APPLICATION DEFECTIVE No. - 136 of 2026 Court No. - 7 HON'BLE PIYUSH AGRAWAL, J. (Civil Misc. Exemption Application) The application is allowed. The applicant is exempted from filing the certified copy of the order dated 25.3.2026. (order passed in the review application) Heard learned counsel for the applicant and Mr. Dhananjay Awasthi, learned counsel for the opposite party. By means of present review application, the applicant is seeking clarification of the order dated 25.3.2026 to the extent that 10 % amount is to be computed on the alleged liability and specify the forum where such deposit is to be made. Learned counsel for the applicant submits that the order dated 25.3.2026 needs some correction / modification but the nomenclature of the present application is inadvertently changed as review application instead of correction / modification application. Learned counsel for the applicant further submits that by the order dated 25.3.2026, the applicant was directed to deposit the 10 % amount but place, where such amount is to be deposited, has not been mentioned, therefore, the order could not be complied with within time. Further in the Versus Counsel for Applicant(s) : Gyanendra Kumar Yadav Counsel for Opposite Party(s) : A.S.G.I., Dhananjay Awasthi M/S Maple Leaf Intelligent Solution Pvtltd .....Applicant(s) Union Of India And 5 Other .....Opposite Party(s) 2nd paragraph of the order, the assessment year 2017-18 has been shown though the applicant has approached this Court for Assessment Years 2017-18 and 2018-19. After hearing learned counsel for the parties, the Court has perused the records. In view of above, 2nd and 7th paragraph of the order dated 25.3.2026 is modified to the following extent:- 2. Learned counsel for the petitioner submits that the proceedings under Section 122 for levying penalty have been initiated against the petitioner without there being any authority as the provision came into force on 01.01.2021 whereas the relevant assessment year are 2017-18 and 2018-19. At the relevant time, there was no such provision, therefore, the proceedings have been initiated wrongly. She further submits that that notices were issued under CGST and SGST but surprisingly, the order was passed under IGST which is beyond jurisdiction. .. 7. Till the next date of listing, no coercive action shall be taken against the petitioner provided that the petitioner deposits 10% of the alleged outstanding amount of demand, within two weeks from today before the assessing authority." The review/modification application is disposed of accordingly. May 5, 2026 Rahul Dwivedi/- CMRAD No. 136 of 2026 2 (Piyush Agrawal,J.) Digitally signed by :- RAHUL DWIVEDI High Court of Judicature at Allahabad