Seizure under Section 67 invalid without recorded reason to believe; seized items must be returned if no six-month notice issued.

Seizure under Section 67 is lawful only where the proper officer records a bona fide reason to believe that specific goods, documents, books or things are useful or relevant to proceedings; absence of a recorded rational connection between available material and that belief renders any seizure invalid. Separately, if the notice required by Section 67(7) is not issued within six months (absent a statutory extension), the statutory consequence is return of the seized items to the person from whose possession they were taken. Both defects independently mandate release of seized cash and return with applicable interest.

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Issues: (i) Whether seizure of cash found at premises could be validly made under Section 67(2) of the Central Goods and Services Tax Act, 2017; (ii) Whether failure to issue notice within six months under Section 67(7) of the Central Goods and Services Tax Act, 2017 requires return of seized goods (cash).

Issue (i): Whether cash seized during search can be treated as "things" under Section 67(2) of the Central Goods and Services Tax Act, 2017 and whether the seizure complied with the statutory requirement of "reason to believe".

Analysis: Section 67(2) permits seizure of goods, documents, books or things if the proper officer has reason to believe they are useful or relevant to proceedings. The legal standard of "reason to believe" requires a rational connection between material available to the officer and the belief that the items are relevant to proceedings; the officer must record reasons supporting that belief. The seizure of cash must satisfy these statutory preconditions and be confined to items demonstrably useful or relevant to proceedings under the Act.

Conclusion: The seizure of cash was invalid. The statutory precondition of a recorded "reason to believe" and the requisite connection to proceedings under Section 67(2) were not fulfilled; accordingly the cash seizure under that provision could not be sustained.

Issue (ii): Whether, independent of issue (i), the Respondents' failure to issue the notice within six months under Section 67(7) of the Central Goods and Services Tax Act, 2017 obliges return of the seized items.

Analysis: Section 67(7) mandates return of seized goods if no notice in respect thereof is issued within six months, subject only to the statutory extension. Non-compliance with this timeline triggers the statutory consequence of return to the person from whose possession the goods were seized. Where the procedural requirement is unmet and no sufficient extension is shown, the statutory consequence follows.

Conclusion: The failure to issue the statutory notice within six months required return of the seized cash to the person from whose possession it was taken.

Final Conclusion: The impugned seizure of cash was unlawful for lack of the statutory "reason to believe" required by Section 67(2) and for failure to comply with the notice requirement of Section 67(7); accordingly the seizure orders were quashed and the seized cash was ordered to be released with applicable interest.

Ratio Decidendi: Seizure under Section 67 of the Central Goods and Services Tax Act, 2017 is valid only where the proper officer has recorded a bona fide "reason to believe" that specific goods, documents, books or things are useful or relevant to proceedings and notices required by Section 67(7) are issued within the statutory period; absence of these preconditions renders the seizure unlawful and mandates return of the seized items.

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