` 161 IN THE HIGH COURT OF PUNJAB AND HARYANA M/s Sneha Export Union of India and others CORAM: HON’BLE HON’BLE MR. JUSTICE Present: Mr. Mr. Sagar Ratusaria, Sr. Standing Counsel for the revenue. Ms. Aarushi Garg, Advocate for respondent ASHWANI KUMAR MISHRA, A.C.J. 1. Petitioner is aggrieved by the provisional attachment order issued in Form GST DRC (Annexure P/3) been issued beyond a period of one year. 2. Reliance is placed on the provisions of Section 83(2) of the CGST/HGST Act, 2017 “83. Provisional attachment to prot (1) xx xx xx (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 3. Learned counsel for the revenue does not disp law and in facts. IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH CWP-22524 Date of Decision: Sneha Export …Petitioner Vs. Union of India and others …Respondent HON’BLE THE ACTING CHIEF JUSTICE HON’BLE MR. JUSTICE ROHIT KAPOOR Mr. Manav Bajaj, Advocate for the petitioner. Mr. Sagar Ratusaria, Sr. Standing Counsel for the revenue. Ms. Aarushi Garg, Advocate for respondent *** ASHWANI KUMAR MISHRA, A.C.J. (Oral) Petitioner is aggrieved by the provisional attachment order issued in Form GST DRC-22 dated 28.10.2021 (Annexure P/2) and (Annexure P/3), primarily on the ground that such attachment could not have been issued beyond a period of one year. Reliance is placed on the provisions of Section 83(2) of the CGST/HGST Act, 2017, which is reproduced as under: “83. Provisional attachment to prot (1) xx xx xx (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).” Learned counsel for the revenue does not disp law and in facts. IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH 22524-2026 (O&M) Date of Decision: 23.07.2026 …Petitioner …Respondents THE ACTING CHIEF JUSTICE ROHIT KAPOOR , Advocate for the petitioner. Mr. Sagar Ratusaria, Sr. Standing Counsel for the revenue. Ms. Aarushi Garg, Advocate for respondent No.4. (Oral) Petitioner is aggrieved by the provisional attachment order issued in 22 dated 28.10.2021 (Annexure P/2) and order dated 03.11.2022 , primarily on the ground that such attachment could not have Reliance is placed on the provisions of Section 83(2) of the , which is reproduced as under:- “83. Provisional attachment to protect revenue in certain cases. (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 Learned counsel for the revenue does not dispute the proposition in Petitioner is aggrieved by the provisional attachment order issued in 03.11.2022 , primarily on the ground that such attachment could not have Reliance is placed on the provisions of Section 83(2) of the (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 ute the proposition in RAJESH KUMAR 2026.07.24 11:25 I attest the accuracy and authenticity of this order/judgment. CWP-22524-2026 (O&M) [2] 4. Once the maximum period of attachment has expired, there is no occasion for the revenue to continue with such attachment for such long period of time. 5. In that view of the matter, the writ petition succeeds and is allowed and attachment order dated 28.10.2021 (Annexure P/2) and order dated 03.11.2022 (Annexure P/3) are quashed. However, it shall always be open for the authorities to proceed further, in accordance with law. 6. All pending misc. application(s), if any, also stand disposed of. (ASHWANI KUMAR MISHRA) ACTING CHIEF JUSTICE (ROHIT KAPOOR) JUDGE 23.07.2026 rajesh 1. Whether speaking/reasoned? : Yes/No 2. Whether reportable? : Yes/No RAJESH KUMAR 2026.07.24 11:25 I attest the accuracy and authenticity of this order/judgment.