Provisional GST attachment can be renewed after expiry when fresh material shows prima facie tax evasion and revenue risk.

Provisional attachment of bank accounts under GST may be renewed after the earlier attachment expires, if fresh satisfaction is recorded on later material showing a prima facie case of tax evasion and a live nexus with revenue protection. On the facts discussed, the record included search material, satisfaction notes, the taxpayer's statement, and an intimation under section 74(5), which supported continued attachment to safeguard revenue during the investigation into alleged fraudulent invoicing and wrongful input tax credit. Objections based on expiry, delay, or lack of jurisdiction did not justify interference where no legal infirmity was shown.

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Issues: Whether the renewal and continuation of provisional attachment of the petitioner's bank accounts under section 83 of the Goods and Services Tax enactment was liable to be quashed on the grounds of expiry of the earlier attachment, alleged lack of jurisdiction, and absence of sufficient material.

Analysis: The proceedings arose from search action and investigation into alleged fraudulent invoicing and wrongful availment of input tax credit. The material on record, including the satisfaction notes, the petitioner's statement, and the intimation under section 74(5), showed a prima facie case of tax evasion and a live connection between the investigation and the need to secure revenue. Although every provisional attachment ceases to operate after one year under section 83(2), the expiry of the earlier attachment did not prevent the authority from passing a fresh or renewed attachment order upon recording satisfaction on the later dates. The objections based on delay, non-disposal of earlier objections, and reliance on contrary precedent did not warrant interference in the facts of the case. The Court also found the revenue-protective measure justified in view of the alleged fraudulent billing pattern and quantified liability emerging from the investigation.

Conclusion: The provisional attachment was upheld and the challenge to the impugned renewal orders failed.

Final Conclusion: The petition was rejected as the Court found no ground to interfere with the attachment orders made to safeguard revenue during the ongoing investigation.

Ratio Decidendi: Where the record discloses tangible material showing prima facie tax evasion, the authority may, after the earlier provisional attachment expires by operation of law, record fresh satisfaction and continue attachment under section 83 to protect revenue, and such action will not be interfered with absent legal infirmity.

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