https://www.taxtmi.com/caselaws?id=447677 Provisional attachment under GST is an exceptional power that can be exercised only on tangible material and with a recorded formation of opinion showing why revenue protection is necessary. The communicated Form GST DRC-22 order itself must disclose the reasons, so the assessee can understand the action and, where the scheme permits, object effectively; reasons noted only in the file are insufficient. A later counter affidavit or assessment order does not cure a defective attachment order, because legality is judged on the order as passed. The omission to record reasons showed non-compliance with the mandatory requirement, so the attachment was unsustainable and set aside. en-us Wed, 27 Dec 2023 00:00:00 +0530 Fri, 25 Apr 2025 12:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=447677 Provisional attachment under GST is an exceptional power that can be exercised only on tangible material and with a recorded formation of opinion showing why revenue protection is necessary. The communicated Form GST DRC-22 order itself must disclose the reasons, so the assessee can understand the action and, where the scheme permits, object effectively; reasons noted only in the file are insufficient. A later counter affidavit or assessment order does not cure a defective attachment order, because legality is judged on the order as passed. The omission to record reasons showed non-compliance with the mandatory requirement, so the attachment was unsustainable and set aside. Case-Laws GST Wed, 27 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=447677