Seizure of Cash: money is excluded from 'goods' under GST and cannot be retained absent demonstrable evidentiary value.

Whether GST authorities may seize cash under Section 67 is analysed by construing the statutory phrase "documents or books or things" ejusdem generis with documents and books, and by noting that the Act's definition of goods excludes money. The legal principle applied is that cash may be retained only if particular currency or cash in specie has demonstrable evidentiary value directly correlatable to transactions or material relevant to proceedings; mere unaccounted or suspicious cash is insufficient. Operatively, absent such evidentiary link the seizure power does not extend to the cash seized and it must be de-sealed.

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Issues: Whether the respondent GST authorities have the power under Section 67 of the Central Goods and Services Tax Act, 2017 to seize cash retained at the petitioners' premises and whether the specific cash of Rs. 24,00,000 may be de-sealed and released to the petitioners in the facts of this case.

Analysis: Section 67(2) authorises seizure of goods or "documents or books or things" that the proper officer has reason to believe are useful or relevant to proceedings under the Act. Section 2(52) defines "goods" and expressly excludes money. The statutory scheme shows that seizure power is directed at goods liable to confiscation and at documents/books/things that contain information useful for proceedings; such "things" must be understood ejusdem generis with documents and books and limited to items yielding relevant information. Currency or cash can be seized only where particular currency notes or cash in specie have demonstrable evidentiary value capable of being correlated to transactions or other material relied upon in proceedings; mere finding of unaccounted wealth or suspicion of unaccounted cash does not, without more, permit seizure under Section 67.

Conclusion: The respondents did not demonstrate that the seized cash of Rs. 24,00,000 is useful or relevant to proceedings under the Act or that the currency can be correlated to any transaction required to be established; accordingly, the GST authorities had no power under Section 67 to seal and retain that cash in these facts. The cash of Rs. 24,00,000 is directed to be forthwith de-sealed so that the petitioners may use it in accordance with law.

Ratio Decidendi: Section 67(2) of the Central Goods and Services Tax Act, 2017 does not permit seizure of money as "goods"; cash may be retained only if particular currency or cash in specie has demonstrable evidentiary value directly relevant to proceedings under the Act, otherwise seizure of mere unaccounted cash exceeds the statutory power.

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