Expiry of provisional attachment bars renewal of the freeze, and a lapsed bank account attachment cannot be revived.

A provisional attachment under the CGST Act cannot be revived or renewed once the earlier attachment has lapsed by operation of law. The text notes that the first account's attachment had expired, there was no subsisting attachment over the second account, and the renewed attachment of the third account was challenged on the basis that section 83(2) does not permit an expired attachment to be reimposed without authority. The circular relied on was also treated as consistent with the time-bound character of such proceedings. The renewed attachment was held unsustainable, and the account was directed to be defreezed.

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Issues: Whether the third bank account, which had been provisionally attached and whose earlier attachment had lapsed by operation of law, could be attached again and whether the account was liable to be defreezed.

Analysis: The attachment of the first account had already lapsed, there was no subsisting attachment of the second account, and the petitioners challenged the renewed attachment of the third account. The relevant statutory framework under section 83(2) of the Central Goods and Services Tax Act, 2017 was invoked to contend that once the attachment expired, the Department could not revive or renew it without authority. The circular relied upon was also noted as supporting the time-bound nature of proceedings and the effect of expiry under the provision.

Conclusion: The renewed attachment of the third account was held unsustainable and the account was directed to be defreezed, in favour of the petitioners.

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