Provisional attachment under GST needs recorded satisfaction; identical reattachment after earlier quashing exposed the officer to costs and contempt scrutiny.

Provisional attachment of bank accounts under section 83 of the Gujarat GST Act requires recorded satisfaction that the measure is necessary to protect government revenue. On inspection of the original file, no such satisfaction was found, and the impugned attachment was identical to an earlier attachment that had already been set aside despite prior directions and guidelines. The officer was therefore directed to show cause why personal costs should not be imposed and why contempt action should not be considered, with the matter listed for further hearing.

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Issues: Whether the order of provisional attachment of the petitioner's bank accounts under section 83 of the Gujarat Goods and Services Tax Act, 2017 was supported by the requisite recorded satisfaction, and whether the respondent officer's identical attachment order warranted a show-cause notice for costs and possible contempt proceedings.

Analysis: On production of the original file, it was noticed that no satisfaction had been recorded by the concerned officer that provisional attachment was necessary to protect the interest of government revenue. The impugned attachment was also found to be identical to an earlier attachment already set aside, despite prior directions and guidelines governing exercise of power under section 83.

Outcome: The officer was directed to show cause why he should not be personally liable for costs and why the matter should not be referred for contempt consideration; the matter was listed for further hearing.

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