It is cleared by the Bombay high court that provisional attachment power is not a universal power given to the department and it has to be used in certain special situations. The judgment was in the middle of one long decision taken by the court in the writ petition which was filed by the M/s. Gehna Trading LLP. As per the information received by the Deputy Commissioner, Central Goods and Service Tax (CGST) 
The Yusuf Fauzdar Shaikh, proprietor of M/s. Fashion Creations has against it the petition from the petitioner while the proceedings stated that the amount was transferred to multiple entities. As per Section 83 of the Central Goods and Services Tax (CGST) Act, 2017 concerned with the “Provisional Attachment power to Protect Revenue in Certain Cases”, let us go through them:
1) Where during the pendency of any proceedings under section 62 or section 63 or section 64 or section 67 or section 73 or section 74, the Commissioner is of the opinion that for the purpose of protecting the interest of the Government revenue, it is necessary so to do, he may, by order in writing attach provisionally any property, including bank account, belonging to the taxable person in such manner as may be prescribed. (2) Every such provisional attachment shall cease to have effect after the expiry of a period of one year from the date of the order made under sub-section (1).
Read Also: Latest GST Notifications 2019 & 2020 for Central Tax, Integrated Tax 
The court stated and assumed that the section 62, 63, 64, 67, 73 and 74 mentioned in section 83 of the Act are not applicable to the petitioner but issued summon as per the pursuant to the inquiry adding the M/s. Maps Global under section 67 of the Act, as per the summon. Therefore the judges said that the attachment powers might come to rescue the government revenue but are still not acceptable to apply them to any situation without properly understanding them.
