Provisional enforcement suspension where taxpayer offers documents; require prompt submission and expedited administrative consideration.

Garnishee attachment in relation to a disputed GST recovery should be suspended where the taxpayer has offered to furnish supporting credit notes and returns and there is no reasonable apprehension of evasion. The article prescribes that the taxpayer must supply outstanding documents within a short, specified period and the tax authority must expeditiously consider those submissions within a defined timeframe before enforcing bank attachment. The approach rests on proportionality and procedural fairness: interim enforcement is inappropriate absent urgent risk, and expedited administrative consideration protects the taxpayer's banking operations pending final decision.

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Issues: Whether the garnishee notice issued by the tax authority to the petitioner's banker and resulting hold on the petitioner's bank account should be withdrawn pending submission and consideration of documents by the petitioner in relation to a disputed GST recovery demand.

Analysis: The record shows that credit notes and related return filings were previously communicated by the petitioner and that the petitioner has offered to furnish all supporting documents and clarifications. The tax authority issued statutory recovery intimation and thereafter a garnishee notice placing a hold on the petitioner's bank account before completing consideration of the petitioner's explanations and documentary material. Given the petitioner's readiness to produce documents and the availability of a process for the authority to examine the materials, the garnishee notice operates as an immediate and disproportionate interference with the petitioner's banking operations. It is appropriate to require the petitioner to submit the outstanding documents within a short, specified period and to require the authority to consider the submissions within a defined timeframe while protecting the petitioner from immediate attachment where there is no reasonable apprehension of evasion and where the petitioner is a reputed entity.

Conclusion: The garnishee notice dated 3rd February 2026 issued to the petitioner's banker shall be withdrawn forthwith and shall not be acted upon; the petitioner shall submit the required documents within ten days of service of the order and the authority shall consider the submissions and take an appropriate decision within one month of receipt.

Final Conclusion: The matter is disposed of by permitting the petitioner an opportunity to furnish documents and by directing the tax authority to decide on recovery after consideration of the materials within a fixed period; the interim withdrawal of the garnishee notice preserves the petitioner's right to operate its bank account pending such decision.

Ratio Decidendi: Where a taxpayer has shown readiness to furnish documentary proof and there is no reasonable apprehension of evasion, provisional enforcement by garnishee/attachment should be withdrawn pending fair opportunity for submission and expedited consideration by the tax authority.

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