Tax payment on summon

This discussion addresses a situation where a GST summon was issued concerning ITC claimed on fake invoices. The taxpayer voluntarily reversed the ITC via DRC-03 before a show cause notice was issued, but did not pay the associated interest and penalty, citing an instruction. The department has now issued a notice demanding payment. The core question is whether penalty is applicable for voluntary ITC reversal without a show cause notice, and how different sections of the GST law (like 74(5), 74(8), 74(11), and 122) impact the penalty rates based on the timing of tax payment.