GMG Tradelink Pvt. Ltd. Vs Directorate General of GST Intelligence HQ & Ors. (Delhi High Court)
The Delhi High Court, in the case of GMG Tradelink Pvt. Ltd. Vs Directorate General of GST Intelligence HQ & Ors., addressed a challenge to an order dated March 6, 2025, passed by the Principal Additional Director General, Directorate General of GST Intelligence, Headquarters, which directed the provisional attachment of the petitioner’s two current bank accounts. The petitioner, M/S GMG Tradelink Pvt. Ltd., contested the provisional attachment order, asserting that the issuing authority, the Principal Additional Director General, was not duly authorized to exercise such powers under Section 83 of the Central Goods and Services Tax Act, 2017 (CGST Act). Section 83(1) of the CGST Act grants the power of provisional attachment to the Commissioner when deemed necessary to protect government revenue, after the initiation of proceedings under Chapter XII, XIV, or XV. The petitioner also stated that it had previously filed objections regarding the Authority’s competence on September 2, 2025, with the Commissioner, DGGI, New Delhi, under Rule 159(5) of the CGST Rules, 2017.
The respondent, represented by the Senior Standing Counsel (SSC), countered the petitioner’s argument by producing Notification No. 14/2017-Central Tax, dated July 1, 2017, issued by the Central Board of Excise and Customs. This notification was cited to establish that the Principal Additional Director General, Goods and Services Tax Intelligence is invested with all the powers exercisable by the Central Tax Officer of the corresponding rank, specifically the Principal Commissioner, Goods and Services Tax. According to the table within the notification, the Principal Additional Director General of Goods and Services Tax Intelligence corresponds to the rank of Principal Commissioner. Based on this notification, the court concluded that the petitioner’s plea regarding the lack of authorization of the Principal Additional Director General was not sustainable.
