Stunning Dentistry Vs Union of India & Anr. (Delhi High Court)
The petition challenged an order dated 24 February 2026 by which the petitioner’s bank accounts were provisionally attached under Section 83 of the GST Act. The attachment arose from search and seizure proceedings conducted by the respondent authorities. According to the respondent, the petitioner was engaged in activities liable to GST and had been issued various summons. Although replies were submitted, the respondent alleged that the petitioner was not cooperating in the investigation and, in order to protect the revenue, exercised powers under Section 83 to provisionally attach the bank accounts.
The petitioner contended that it had extended full cooperation during the proceedings and had already provided all relevant documents, including invoices, which were in the custody of the respondent. It was argued that the freezing of bank accounts had brought the petitioner’s business activities to a standstill, preventing payment of rent, salaries, and other day-to-day operational expenses. The petitioner submitted that the interests of the revenue could be adequately protected by imposing reasonable conditions while permitting operation of the bank accounts.
The respondent opposed the petition, asserting that the petitioner had failed to pay GST on services that were chargeable under the GST regime. It was argued that the alleged violation and consequent revenue implications justified the exercise of powers under Section 83. The respondent further contended that even though documents had been seized or supplied, the investigation was still ongoing and a show cause notice had yet to be issued, making the provisional attachment necessary.
