M/s SHRI PETRO CHEMICAL MERCANTILE PVT. LTD. v. THE UNION OF INDIA & ORS.

Introduction

The petitioner, M/s Shri Petro Chemical Mercantile Pvt. Ltd., challenged the Provisional Attachment Order dated 27.02.2026 issued under Section 83 of the CGST Act, whereby its bank account maintained with Punjab & Sind Bank, Dimapur Branch, was provisionally attached.

The petitioner contended that the attachment order had been passed mechanically without recording the mandatory satisfaction or opinion contemplated under Section 83. According to the petitioner, the impugned order merely stated that the attachment was necessary “to protect the interest of Government revenue” without disclosing any independent formation of opinion by the competent authority.