Writ petition show petitioner-company duly registered under the GST Act, 2017 was subjected to inspection on 1st December 2018 by the Assistant Commissioner of Commercial Taxes and asked to furnish a set of documents before the Deputy Commissioner of Sales Tax on 4 th December, 2018 under Section 71 of the JGST Act, 2017. According to the petitioner relevant documents such as purchase register with copy of invoices and vender wise detail of GST credit for the period 1 st July, 2017 to 31st October, 2018 and stock register for financial year 2017-18, 2018-19 were furnished. However, according to the petitioner as per the agreement with the ONGC and IOCL the project executed by the petitioner was at this stage of installation/erection/commission and as on that date 19th July, 2019 no revenue had been generated. However, petitioner received a summary of show cause notice under GST DRC-01/GST DRC-02 alleging availment of excess Input Tax Credit for the period July, 2017 to September, 2018 proposing to impose tax, interest and penalty to the tune of Rs. 1.09 crores. Petitioner’s return were also subjected to scrutiny and GST ASMT-10 was issued in terms of Rule 99 (1) for the period of April, 2018 to March, 2019 which overlaps to the period of DRC-01/ DRC-02 alleging mismatch of GSTR-3B and GSTR-2A. Subsequently petitioner was surprised to receive a summary of the order under GST DRC-07 issued under Rule 142(5) for the period July, 2017 to September 2018. According to the petitioner it filed an application for rectification on 28th September, 2019 under Section 161 of the Act of 2017 and also submitted reconciliation statements for the period of 1st July 2017 to 30th September 2018 in terms of which an amount of Rs. 4.06 lacs was standing towards ITC in favour of the petitioner. According to the petitioner as per the reconciliation statements there is no difference or mismatch or excess availment of ITC. The grievance of the petitioner is that no order has been passed on the rectification application till date while an amount of Rs. 74.20 lacs of ITC remains blocked in its Electronic Credit Ledger since 16th February 2020 till date much beyond the one year period prescribed under rule 86 A of the JGST Act, 2017. Petitioner has inter-alia taken up number of grounds and urged that the writ petition is maintainable on account of violation of principles of natural justice and failure to follow the procedure prescribed in law before passing an adverse order imposing tax, interest and penalty upon the petitioner under Section 73 of the JGST Act. Petitioner has also taken a plea that in case the respondents have under taken scrutiny of the return submitted by the petitioner under Section 61 of the JGST Act and issued ASMT-10 showing mismatch or discrepancy in his returns, petitioner was entitled to avail of the statutory period to remove such discrepancy or seek a rectification thereof under Section 161 of the JGST Act. The respondents have kept the application for rectification pending and instead blocked the ITC lying in the Electronic Credit Ledger of the petitioner for more than one year. Therefore, summary of the order contained in GST DRC07 (Annexure-12) be quashed and the respondents may be directed to unblock ITC lying in the Electronic Credit Ledger of the petitioner. At the same time the respondents may also be directed to undertake the rectification of the discrepancy as per the reconciliation statements provided by the petitioner. In case the rectification exercise leads to adverse order against the petitioner, he may be allowed the liberty to assail it before the appellate authority under Section 107 of the JGST.