JUDGMENT :

R.D. DHANUKA, J.

Rule. Mr.Mishra, learned counsel for the respondents waives service. By consent of parties, writ petition is heard finally.

2. By this petition filed under Article 226 of the Constitution of India, the petitioner has prayed for a declaration that the circular dated 23rd February, 2021 is ultra vires the provisions of the Central Goods and Services Tax Act, 2017 (for short CGST Act, 2017) or in the alternative to read down the circular dated 23rd February, 2021 to make the recording of reasons or grounds of attachment mandatory in the attachment order or Form DRC-22 issued in terms of Rule 159(1) of the CGST Rules.

3. The petitioner also prays for writ of certiorari for quashing and setting aside the impugned freezing orders dated 7th December, 2021 issued by the respondent no.3 and further seeks writ of mandamus in terms of prayer clause (d) of the petition.

4. It is the case of the petitioner that the petitioner purchased the goods locally from wholesale traders which are consolidated at the level of the wholesale trader and thereafter are dispatched to the warehouse of the logistics company, from where the goods are sent to the CFS Terminals at the customs