1. We have heard Mr. Hardik Vora, the learned counsel appearing for the writ applicant.

2. Let Notice be issued to the respondents, returnable on 24.02.2021. As the constitutional validity of sub-section (4) of the Section 16 of the Central Goods and Services Tax Acts, 2017 has been challenged on the ground of being arbitrary, discriminatory and violative of Articles 14, 19 and 300A respectively of the Constitution of India, Notice shall also be issued to the Attorney General of India.

3. Prima facie, it appears that the impugned recovery order / Notice dated 20.10.2020 is without any show-cause or assessment proceedings. Till the next date of hearing, there shall not be any coercive recovery proceedings towards the dues pursuant to the recovery order dated 20.10.2020 (at Annexure-A to this petition).

4. To be heard along with Special Civil Applications Nos.5268 and 4031 of 2020.