Court upholds denial of seized document copies under CGST Act citing risks of interference. Discretion valid, appeals available.

The High Court upheld the competent authority's decision to deny copies of seized documents under Sec. 67(5) of the CGST Act, citing risks of manipulation and interference with the investigation. The court found the authority's discretion judiciously exercised and no jurisdictional error in the decision. As statutory appeal was an available remedy, the court dismissed the petitions challenging tax liability, interest, and penalty for various assessment years at the admission stage, without costs.

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Issues involved:
Petitions assailing tax liability, interest, and penalty for different assessment years due to denial of copies of seized documents under Sec. 67(5) of the CGST Act.

Analysis:
1. Denial of Copies of Seized Documents:
- Petitioner challenged tax liability, interest, and penalty for different assessment years due to denial of copies of seized documents, alleging violation of principles of natural justice.
- Search conducted at petitioner's firm led to seizure of certain documents, with some handed over and some seized by official respondents.
- Petitioner requested copies of seized documents but was denied by competent authority under Sec. 67 of the CGST Act, citing concerns of potential manipulation or interference with investigation.
- Despite multiple opportunities, petitioner failed to produce all required documents, leading to an ex parte decision by the competent authority on tax liability.

2. Legal Arguments and Precedents:
- Petitioner relied on legal precedents from Bombay High Court, Kerala High Court, and Supreme Court to argue that Sec. 67 of the CGST Act obliges the competent authority to supply copies of seized documents unless it prejudicially affects the investigation.
- Emphasized that the supply of copies would not enable manipulation or interference once documents are seized by the authority during the search.

3. Court's Decision:
- The court declined admission to the petitions, finding that the competent authority had exercised discretion judiciously in withholding copies of seized documents to prevent potential manipulation.
- Reasoned that the authority's opinion on adverse effects on the investigation was reasonable, and no jurisdictional error was found in the impugned order.
- Since the statutory appeal remedy was available but unavailed, the court dismissed all three petitions at the admission stage without costs.

In conclusion, the High Court upheld the competent authority's decision to deny copies of seized documents, considering the potential risks of manipulation and interference. The court emphasized the authority's judicious exercise of discretion under Sec. 67(5) of the CGST Act and the availability of statutory appeal as an alternative remedy, leading to the dismissal of the petitions challenging tax liability, interest, and penalty for different assessment years.

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