Karan Singh Security Agency Private Limited Vs State of Odisha and others (Orissa High Court)
The Orissa High Court disposed of a writ petition filed by a private security company seeking revocation of bank attachment orders issued under Section 79 of the GST Act and permission to pay admitted GST dues in installments.
The petitioner company was assessed to tax under the CGST Act and OGST Act pursuant to a show-cause notice in Form GST DRC-01 concerning mismatch in GSTR-2A returns for June 2025, August 2025 and November 2025. The total demand raised was ₹2.49 crore, including tax and interest.
The petitioner submitted that it was unable to discharge its tax liability because payments from various organizations for services rendered had not yet been cleared. It informed the authorities that it expected to receive approximately ₹9.54 crore from different organizations, but despite this, attachment orders issued under Section 79 against its bank accounts were not revoked. The petitioner admitted the liability and requested time to pay the dues in installments.
The GST Department opposed the plea, contending that there was no statutory provision permitting payment of admitted tax liability in installments. It was also pointed out that recovery proceedings had already been initiated under Section 79 and that the petitioner had deposited ₹27.50 lakh each under the CGST and OGST Acts after initiation of recovery proceedings.
