Provisional attachment under GST and efflux of time leave fresh attachment challenges open for separate examination.

Provisional attachment of cash credit accounts under Section 83 of the CGST Act was considered in relation to whether it had ceased by efflux of time and whether a fresh attachment order, including repeated attachment, could be examined in the same proceedings. The petition was disposed of because the impugned order had already ceased to operate. Liberty was reserved to challenge the fresh attachment order in accordance with law, and the question of repeated issuance of attachment orders was left open.

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Issues: Whether the provisional attachment of the cash credit accounts under Section 83 of the Central Goods and Services Tax Act, 2017 had ceased to operate by efflux of time, and whether the validity of a fresh attachment order and repeated attachment could be examined in these proceedings.

Outcome: The petition was disposed of because the impugned order had ceased to operate, liberty was reserved to challenge the fresh attachment order in accordance with law, and the question regarding repeated issuance of attachment orders was left open.

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