Taking note of these dates and events and contention of the petitioner, we feel not to entertain the Interlocutory Application insofar as bringing of certain documents of NIT read with the later development order dated Patna High Court CWJC No.10851 of 2023 dt.13-10-2023 4/4 01.08.2023. Accordingly, the present writ petition stands dismissed reserving liberty to the petitioner to file a fresh writ petition.

The issue of limitation, if any, is left open to be raised before the Arbitral Tribunal. Joint Registrar (List) is directed to communicate the order to the learned Arbitrator. Learned counsel for the parties also undertake to communicate the order to the learned Arbitrator. The Arbitral Tribunal shall issue notice to the respondents. The Request Petition stands disposed of in the above terms.

We are of the opinion that the order clearly shows the dates and there is nothing to be verified as of now. The Department cannot come forth with an argument that in fact, the order was passed subsequent to 14.08.2023, since the order clearly indicates the date of 24.08.2023.

The proceedings as initiated against Annexure-1 dated 04.02.2022 by the State Tax Authority, is at the notice stage and with respect to one of the years on which the Central Tax Authority has already initiated proceedings. Annexure-1, hence, Patna High Court CWJC No.2668 of 2023 dt.10-10-2023 10/10 shall be kept in abeyance. We make it clear that any documents or materials produced before the State Tax Authority shall be transmitted to the Central Tax Authority. The petitioner shall appear before the Central Tax Authority in compliance of Annexure-3.

The issue of limitation, if any, is left open to be raised before the Arbitral Tribunal. Joint Registrar (List) is directed to communicate the order to the learned Arbitrator. Learned counsel for the parties also undertake to communicate the order to the learned Arbitrator. The Arbitral Tribunal shall issue notice to the respondents. The Request Petition stands disposed of in the above terms.