2025 (9) TMI 1147

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....of Goods and Services Tax Intelligence, Gurugram Zonal Unit (hereinafter, 'DGGI'). 3. The Petitioner engaged in the manufacture of food products and was served with the Show Cause Notice (hereinafter, 'SCN') on 2nd February, 2024. In respect of the said SCN, the bank account of the Petitioner was attached vide order dated 7th March, 2024. The said bank account is as under: ● Bank: HDFC Banks ● Branch: Rohini ● Account No.: 50200001632681 4. The Petitioner sought defreezing of the bank account which was rejected vide order dated 15th July, 2024 in the following terms: "Order It is necessary to keep the bank account Number 50200001632681 (HDFC BANK LTD. BLOCK NO.5, SECTOR 11, ROHI....

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....ery such provisional attachment shall cease to have effect after the expiry of a period of one year from the date of the order made under sub-section (1)." 6. This issue has already been considered by this Court in Krish Overseas v. Commr., Central Tax, 2024 SCC OnLine Del 2865 wherein it has been observed as under: "4. Section 83 of the Act, under which the impugned communication dated 14.08.2019 has been issued, reads as under:- "83. Provisional attachment to protect revenue in certain cases. (1) Where during the pendency of any proceedings under section 62 or section 63 or section 64 or section 67 or section 73 or section 74, the Commissioner is of the opinion that for the purpose of protecting the interest of ....