Considering that the State penalty proceedings had concluded and were under appeal, while the Central proceedings were still pending, the Court directed that the Central show cause notice dated 19.09.2025 be kept in abeyance until disposal of the State appeal. The Appellate Authority of the State Tax Department was directed to conclude the appeal within four weeks. It held that the Central Tax authorities could proceed with the show cause notice only after conclusion of the State appellate proceedings. The Central authorities were directed to consider the findings of the State Appellate Authority while deciding the matter. The proceedings by the State tax authorities has ended in imposition of penalty by order dated 21.04.2025.