As per case facts, a search action led to the issuance of show cause notices to M/s. Shemaroo Entertainment Ltd. and its employees (petitioners: CFO, CEO, Director, JMD) for alleged ... ineligible Input Tax Credit (ITC) availment and passing on. Petitioners were arrested and later granted bail, retracting their statements. An order was subsequently passed, imposing significant penalties on the petitioners. The petitioners challenged this Order, arguing lack of jurisdiction, disproportionate penalties, and impermissible retrospective application of Section 122(1A) of the CGST Act, citing a previous High Court judgment in Shantanu Sanjay Hundekari v. Union of India, which was upheld by the Supreme Court. The question arose whether Section 122(1A) applies to employees who are not 'taxable persons' and if its retrospective application is valid. Finally, the High Court concluded that the show cause notices and Order against the Petitioners were without jurisdiction, as employees are not 'taxable persons' and no personal benefit retention was proven. The retrospective application of Section 122(1A) for the period before its effective date was also deemed unsustainable.