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No GST SCN & Demand Not Quantified—Limited Operation of Attached Bank A/c Allowed

Case Law Details

TaxGuru Citation
2026 taxguru.in 128
Case Name
SL Golden Paptech Pvt. Ltd. Vs Principal Additional Director General (Delhi High Court)
Date of Judgement/Order
Only available for paid members
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SL Golden Paptech Pvt. Ltd. Vs Principal Additional Director General (Delhi High Court)

The Delhi High Court considered a writ petition challenging provisional attachment orders dated 28 March 2025 (bank accounts) and 11 April 2025 (immovable properties). The attachments were made prior to issuance of any show cause notice. The Department, in its counter affidavit, alleged GST evasion and stated that the petitioner’s total liability, including tax, penalty, and interest, was about ₹17.92 crore, with the tax component quantified at ₹8.96 crore, and further claimed that data for three financial years could not be found during search proceedings.

The petitioner submitted that ₹2 crore had already been deposited, amounting to nearly 25% of the stated tax liability, and that two immovable properties in North West Delhi had already been provisionally attached. It was also pointed out that the attached bank account had a balance of about ₹1.2 crore and that the attached properties were unencumbered. Emphasising that no show cause notice had yet been issued and the demand was not finally quantified, the petitioner sought liquidity for day-to-day business operations.

Considering the overall circumstances, the Court permitted the petitioner to operate the attached bank account subject to maintaining a minimum balance of ₹50 lakh. This relief was made conditional and subject to issuance of a show cause notice and further adjudication. The bank was directed to give immediate effect to the order. The Department was granted liberty to seek modification if any further demand arose. The writ petition was disposed of accordingly, and the next scheduled hearing was cancelled.

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Author Info

CA Sandeep Kanoi
Qualification: CA in Job / Business
Company: Taxguru Consultancy
Location: Mumbai, Maharashtra
Articles Published: 20,886

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