The petitioner had challenged an Order-in-Original under Section 73 after first filing a rectification application under Section 161, which was rejected. It found that the petitioner had acted with due diligence and good faith by filing the rectification application within the prescribed period. Facts:Mr. Debabrata Bhowmick (“the Petitioner”), proprietor of M/s Harekrishna Drugs, is a registered assessee under the CGST Act carrying on business at Nagaon, Assam. 2,01,246/- and thereafter, a Show Cause Notice dated November 22, 2024 (“the SCN”) under Section 73(1) of the CGST Act. Thereafter, the Petitioner filed an appeal in Form GST APL-01 under Section 107 of the CGST Act on May 23, 2025 against the OIO.