Tourism Corporation of Gujarat Limited, Gandhinagar, Gujarat

State Health & Family Welfare Society, Thiruvananthapuram, Kerala

Municipal Council Barodiya Kalan, Barodiya Kalan, M.P.

Assam Agricultural University, Jorhat, Assam

Sardar Patel Institute Of Public Administration, Ahmedabad, Gujarat

H.P. State Cooperative Bank Ltd., Shimla, Himachal Pradesh

Gujarat Energy Development Agency, Gandhinagar, Gujarat

Municipal Council Shahpur, Shahpur, M.P.

Institute Of Cost Accountants Of India, Kolkata, West Bengal

The petitioner challenged the validity of Notifications extending GST time limits under Section 168A of CGST Act, arguing they lacked GST Council recommendations. The Bombay High Court acknowledged that the issue is pending before the Supreme Court and granted interim relief, restraining authorities from enforcing the disputed GST demand order until final adjudication of the matter.

The High Court upheld the provisional attachment of the petitioner’s bank account under Section 83 of the GST Act, 2017, finding it justified due to unpaid GST liabilities. The petitioner had collected GST from clients but failed to deposit it. Since the show cause notice was adjudicated, and a final order under Section 74 was issued, the petitioner was directed to file an appeal instead of seeking relief via a writ petition.

The above Writ Petition is filed challenging the impugned Garnishee Notice in Form DRC-13 dated 14th February 2025 issued by the State Tax Officer, Thane Division, Thane (Respondent No. 3) instructing Respondent No. 4 Bank to pay over a sum of Rs. 2,18,77,406/- to the Government for the tax payable by the Petitioner under the GST Act. A challenge is also laid to the impugned order dated 13th August 2024 issued by Respondent No. 3 demanding the aforesaid amount from the Petitioner. Before issuance of the said order, a Show Cause Notice dated 31st May 2024 was also issued. This Show Cause Notice is also challenged in the Writ Petition.