Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
The HC held that the provisional attachment of two of the petitioner's bank accounts under Section 83(1) of the CGST Act had exceeded the statutory one-year limit prescribed in Section 83(2), read with Rule 159 of the CGST Rules. As the attachments, effected via Form GST DRC-22 dated 11.11.2024, had "outlived" the permissible duration, they could not legally subsist thereafter. Noting that counsel for the revenue could not confirm lifting of the attachments post-expiry, the HC declared that such provisional attachment cannot continue beyond one year and accordingly set aside the attachments of the two accounts. The writ petition was allowed in part.
The HC held that the provisional attachment of two of the petitioner's bank accounts under Section 83(1) of the CGST Act had exceeded the statutory one-year limit prescribed in Section 83(2), read with Rule 159 of the CGST Rules. As the attachments, effected via Form GST DRC-22 dated 11.11.2024, had "outlived" the permissible duration, they could not legally subsist thereafter. Noting that counsel for the revenue could not confirm lifting of the attachments post-expiry, the HC declared that such provisional attachment cannot continue beyond one year and accordingly set aside the attachments of the two accounts. The writ petition was allowed in part.
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