Pena;lty rebate before order passed and after order passed - Goods and Services Tax - GST

Dear Sirs, Tax paid after the time limit attracts a 100% penalty before the order is passed. If the Taxpayer has paid the tax with interest after the order is passed within the time limit, he will get a 50% rebate on the penalty. Doesn t such a circumstance cause injustice to the Taxpayer who paid the tax before the order passed? For example, ABC received SCN on 20-09-2024, the tax due was paid belatedly on 31-10-2024. and the Order was passed on 30-11-2024 levying a 100% penalty for the delayed payment. XYZ received SCN on 20-08-2024 and did not pay the tax. The order was passed on 30-11-2024. The tax due was paid on 26-12-2024. and gets a 50% rebate on penalty. ABC was deprived of a 50% penalty rebate for early payment before the order passed.