Court Rules Provisional Tax Attachments Lapse After One Year; No Extensions Allowed Under CGST/SGST Acts.

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....The High Court's decision centers around the interpretation of Section 83 of the CGST/SGST Acts, which deals with provisional attachment orders. The key points are: Section 83(2) clearly states that a provisional attachment order will cease to have effect after one year from its issuance. Unlike the Income Tax Act, the GST Acts do not provide for extending this one-year period. The court held that accepting the Revenue's contention of issuing repeated attachment orders would violate the statute's language and legislative intent. The court relied on Supreme Court precedents like Radha Krishnan Industries and Vodafone International Holdings, which emphasize interpreting statutes based on their plain meaning and not supplying words or giving d.........