Provisional attachment under GST may be lifted against adequate immovable property security, while legality challenge remains open.

Provisional attachment of bank accounts under the CGST Act may be lifted where the taxable person offers immovable property of sufficient value to secure the revenue's interest, and the parties may act on that basis without immediate adjudication of the attachment's legality. The communication before the HC recorded that attached accounts could be released if adequate immovable property was furnished, and the respondents would proceed accordingly if the security met the stated value requirement. The petition was disposed of on that arrangement, with directions for expeditious disposal of the show cause notice, while the petitioner's substantive challenge to the provisional attachment was left open.

---

---

Issues: Whether the provisional attachment of the petitioner's bank accounts could be lifted on furnishing immovable property as security, and whether any adjudication on the legality of the attachment was called for at this stage.

Analysis: The communication placed before the Court recorded that, in terms of the provisional attachment framework under Section 83 of the Central Goods and Services Tax Act, 2017, attached bank accounts could be released if the taxable person offered immovable property sufficient to protect the revenue's interest and of value at least equal to the disputed demand. The petitioner ed that it was willing to offer such security within a stipulated period, and the respondents stated that they would act in accordance with the communication if proper immovable property of adequate value was offered. The petitioner's challenge to the legality of the provisional attachment was expressly kept open.

Outcome: The petition was disposed of by accepting the parties' arrangement for offer and consideration of immovable property in lieu of the bank attachment, with directions for expeditious disposal of the show cause notice, while leaving the petitioner's substantive challenge to the attachment open.

---