Reasoned satisfaction for provisional attachment under GST is mandatory before revenue-protection action can stand.

Provisional attachment under section 83(1) of the CGST Act is valid only where the Commissioner records a written opinion that attachment is necessary to protect Government revenue, and the order itself must disclose those reasons so the action can be tested on challenge. Where the attachment order contains no reasons and the record also does not show any recorded satisfaction, the statutory requirement is not met. The order is therefore unsustainable; in the source text, the attachment was quashed and the matter remitted for fresh consideration if the Commissioner chose to proceed again.

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Issues: Whether the order of provisional attachment passed under section 83(1) of the Central Goods and Services Tax Act, 2017 was sustainable in the absence of reasons reflecting the Commissioner's opinion that such attachment was necessary to protect the interest of Government revenue.

Analysis: Section 83(1) requires the Commissioner to form an opinion in writing that provisional attachment is necessary for protecting revenue. The reasons for such opinion must appear from the order itself so that the action can be tested on challenge. Where the impugned order does not disclose any reasons, and even the material placed from the file does not show such recorded satisfaction, the statutory mandate is not complied with.

Conclusion: The provisional attachment order was unsustainable and was quashed and set aside. The matter was remitted to the Commissioner to record reasons in writing if he considers it fit to proceed again.

Final Conclusion: The petition succeeded, and the provisional attachment could not stand for want of a recorded and reasoned statutory satisfaction.

Ratio Decidendi: An order of provisional attachment under section 83(1) of the Central Goods and Services Tax Act, 2017 is invalid unless it discloses the Commissioner's recorded reasons forming the requisite opinion that attachment is necessary to protect revenue.

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