Since no reply was submitted to the show cause notice, the tax authority passed an adjudication order confirming a demand of ₹1,62,13,140 along with interest and penalty, without granting a personal hearing. To avoid multiplicity of proceedings and conflicting decisions, the Court set aside the adjudication order and remitted the matter back to the tax authority for fresh consideration. The authority was directed to pass a new adjudication order in accordance with law after disposal of the pending special leave petition. The period between the impugned order and the Supreme Court’s decision was directed to be excluded for limitation purposes. (ii) The impugned order at Annexure-A dated 12.03.2023 passed by the 4th respondent N is hereby set aside.