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Provisional GST Attachment Sustained After Misrepresentation of Notice Receipt Date

Case Law Details

TaxGuru Citation
2025 taxguru.in 12104
Case Name
Ebix Technologies Limited Vs Directorate General of GST Intelligence (Delhi High Court)
Appeal Number
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Ebix Technologies Limited Vs Directorate General of GST Intelligence (Delhi High Court)

The Delhi High Court heard the petition filed by Ebix Technologies Limited challenging the Provisional Attachment order issued by the Directorate General of GST Intelligence (DGGI). The case was heard in a hybrid mode, with prior directions issued on 7th November 2025. The Court had directed the Petitioner to file a short affidavit addressing allegations and instructed production of the original DGGI file, including complete note sheets. The official who signed the impugned letter dated 25th September 2025, Mr. Ramakant Tiwari, was directed to remain personally present to explain the communication and timing of the said letter. Meanwhile, the Petitioner was permitted to operate its bank accounts subject to maintaining a minimum balance of ₹1 crore. ICICI Bank was directed to comply with this order without obstruction.

On the subsequent hearing, the Respondent submitted an affidavit and supporting documents showing that the impugned provisional attachment letter dated 25th September 2025 was sent by speed post and delivered on 10th October 2025. This contradicted the Petitioner’s previous claim of receiving the letter on 4th November 2025. The Respondent also clarified that attaching all bank accounts under the same PAN is standard under GST Form DRC-22, pursuant to Section 83 of the CGST Act, 2017.

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Author Info

CA Sandeep Kanoi
Qualification: Graduate, CA in Job / Business, DD
Company: Taxguru Consultancy
Location: Mumbai, Maharashtra
Articles Published: 24,191

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