Section 83 of the CGST Act, 2017 — Provisional Attachment of Bank Accounts –-- The respondent had sanctioned refund in terms of Section 54(5). The department appealed against the said order, and while the same was pending, the respondent No.3 has issued notices dated 08.03.2023 to the bankers of petitioner for provisional attachment of bank accounts. The counsel for the petitioner submitted that petitioners would make the deposit of the entire refund sanction amount of 27.54 crores in a bank account which may be kept under provisional attachment.

Held that:- The Hon’ble High Court directed that the Petitioners shall make a deposit of Rs.28.00 crores in a nationalised bank by way of fixed deposit on or before 14.04.2023 and handover the FDR to respondent No.3 within seven days thereafter. The Petitioners shall cooperate with the summons that may be issued by the respondents. The Respondents shall forthwith withdraw the provisional attachment of bank accounts of petitioner No.1. If there is non-compliance of the above conditions by the petitioners, it would be open to the respondents to take such action as may be deemed appropriate in accordance with law.