GST provisional attachment challenge is premature where the statutory objection procedure has not first been invoked.

The GST provisional attachment regime permits attachment of property, including a bank account, subject to the prescribed statutory procedure. An affected person may file an objection within the stipulated time, after which the Commissioner must grant a hearing and pass a reasoned order on whether the attachment should continue or be lifted. Because the petitioner had not first invoked that post-attachment remedy, the writ challenge was treated as premature. The court declined to examine the merits of the attachment and directed the petitioner to pursue the statutory objection before the Commissioner, leaving all contentions open for decision in accordance with law.

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Issues: Whether the writ petition challenging the provisional attachment of the petitioner's bank account should be entertained without first pursuing the statutory objection procedure under the GST law.

Analysis: The provisional attachment regime permits attachment of property, including a bank account, in the manner prescribed by the GST law. The prescribed procedure provides a post-attachment remedy by which the affected person may object within the stipulated time, after which the Commissioner must grant a hearing and pass a reasoned order on whether the attachment should continue or be lifted. Since that statutory mechanism had not been invoked, the petition was premature. The petitioner's contentions were left open to be urged before the Commissioner, who was directed to decide the objection in accordance with law.

Conclusion: The writ court declined to adjudicate the challenge on merits and directed the petitioner to pursue the statutory objection before the Commissioner.

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