ORDER

The present writ petition is filed challenging the impugned order of provisional attachment of property under Section 83 of the CGST Act, 2017 vide FORM GST DRC-22 dated 13.02.2024, on the premise that it suffers from manifest arbitrariness and in excess of the respondent's jurisdiction under Section 83 of the Central Goods and Services Tax Act, 2017 (hereinafter referred to as “the Act” or “the CGST Act”) .

2. Brief Facts:

2.1. The petitioner is a proprietary concern. The petitioner is engaged in trading of Gold Bullion and Gold Jewellery. The petitioner has been in the above business since 2008. It is submitted by the petitioner that bullion was predominantly procured from M/s.LABH, Ahmedabad and a few other suppliers including M/s.SS Bullion, Chennai, M/s.Shiv Sahay Bullion, Chennai. The sales of such bullion was made primarily to M/s.Silver CZ Jewellers, Chennai, M/s.Vijay Bullion, M/s. Suresh Jewellery. The petitioner is registered as a taxable person under the GST Act. It is submitted that the petitioner had filed its returns and paid appropriate taxes under the GST Act.

2.2. While so, on 26.06.2023 the Senior Intelligence Officer, Directorate General of Goods and Service