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Just because some tax amount is due, tax authorities can't start attaching the properties of taxpayer. The apex court also flayed the HP tax department's stand that providing an opportunity for hearing in connection with an order of attachment was a discretion of the commissioner concerned.

Section 83 of CGST Act, 2017—Provisional Attachment — The Appellant petitioner prayed the High Court for quashing the proceedings initiated by the respondent under section 83 by provisionally attaching the amount receivable by the petitioner from its customer while issuing Form DRC-22. The Hon’ble High court in order dated 01.01.2021 has held that the writ petitioner has not only efficacious remedy, rather alternative remedy under the GST Act, and therefore, the present petition is not maintainable. The appellant challenged this order. The Hon’ble Supreme Court after hearing both sides concluded the arguments and reserved the judgment.
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