Provisional attachment under GST must end once revenue is adequately secured by reversals and payments already made.

Provisional attachment of bank accounts under section 83 of the CGST Act is justified only while necessary to protect government revenue during pending proceedings. Here, the petitioner had already reversed input tax credit and made further substantial payments, so the revenue interest was treated as adequately secured. On that basis, continuation of the attachment was no longer justified, and the attachments were required to be released forthwith.

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Issues: Whether the provisional attachment of the petitioner's bank accounts under section 83 of the CGST Act was justified when the petitioner had already reversed tax credit and paid substantial amounts, and whether the attachments were liable to be released.

Analysis: Section 83 empowers provisional attachment only to protect the interest of the Government revenue during pendency of proceedings under the specified provisions. The Court noted that although a higher liability had been estimated by the revenue, the petitioner had already reversed input tax credit and made further payments, so that the amount already recovered was substantial. On that basis, the Court held that the revenue interest was sufficiently secured and that continuation of attachment was no longer justified.

Conclusion: The provisional attachment of the petitioner's bank accounts was unjustified and the respondent was required to release the attachments forthwith.

Final Conclusion: The petition succeeded and the attached bank accounts were ordered to be released because the revenue stood adequately secured.

Ratio Decidendi: Provisional attachment under section 83 can continue only so long as it is necessary to protect the revenue interest; once the revenue is sufficiently secured by payments or reversals already made, the attachment cannot be sustained.

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