Facts of the
Case
A V Enterprises, a partnership firm controlled by
members of the Gumber family, filed a writ petition as part of a batch of
connected matters led by Genesis Enterprises, challenging inspection, search
and seizure operations conducted by the CGST Department in July 2025. The
searches were conducted at the residential premises of the Gumber family at
Noida and at various business premises in Delhi, including those connected with
A V Enterprises.
The petitioner alleged that the search and seizure
were conducted in an unlawful and arbitrary manner, that CCTV footage from the
residential premises was seized in violation of the right to privacy, that
business premises were illegally accessed and sealed, and that refund
applications were withdrawn and Input Tax Credit was reversed under coercion
and duress.
The GST Department asserted that intelligence
inputs revealed a complex network of interconnected and fictitious firms
controlled by the Gumber family, including A V Enterprises, created solely for
availing and passing on fraudulent Input Tax Credit and claiming inadmissible
GST refunds running into several crores of rupees.
Issues
Involved
Whether the search and seizure conducted under
Section 67 of the CGST Act were without jurisdiction or violative of statutory
safeguards, whether seizure of CCTV footage violated the right to privacy,
whether allegations of coercion in ITC reversal and withdrawal of refund
applications warranted writ interference, and whether the High Court should
interdict GST investigation at a nascent stage.
Petitioner’s
Arguments
The petitioner contended that the panchnamas were
defective, that seizure of CCTV footage from a shared residential premises
violated privacy rights of family members, that the business premises were
forcibly opened and sealed without authority, and that coercive methods were
adopted to force payments through DRC-03 and withdrawal of refund applications.
It was argued that the GST authorities exceeded the scope of powers under
Section 67 of the CGST Act and acted contrary to CBIC instructions and settled
judicial precedents governing search and seizure.
Respondent’s
Arguments
The GST Department submitted that “reasons to
believe” were duly recorded by a competent officer prior to authorisation of
search under Section 67(2) of the CGST Act. It was contended that investigation
revealed multiple layers of non-operational and fictitious firms with nil
inward supplies, circular transactions and refund claims based on fake ITC,
including transactions involving A V Enterprises. The Department stated that
seized CCTV memory cards and electronic devices had not been accessed and would
be examined strictly in accordance with prescribed SOPs and safeguards.
Court Order
/ Findings
The Delhi High Court analysed the scheme and
safeguards of Section 67 of the CGST Act and reiterated that search and seizure
powers, though intrusive, are statutorily sanctioned where “reasons to believe”
exist. The Court found that substantial material had been placed on record
indicating large-scale GST evasion through a maze of fictitious firms created
and controlled by the Gumber family.
The Court held that sufficiency of the reasons
recorded for search cannot be examined in writ jurisdiction and that judicial
interference at the investigation stage would be wholly unwarranted.
Allegations of coercion, illegal sealing and duress were held to involve
disputed questions of fact not amenable to adjudication under Article 226. The
Court also took note of the Department’s categorical assurance that seized CCTV
footage had not been accessed, thereby negating any immediate violation of
privacy.
Important
Clarification
The High Court clarified that Section 67 CGST Act
empowers GST authorities to conduct inspection, search and seizure to unearth
tax evasion and that courts will not interdict investigations merely on
allegations of procedural impropriety unless clear jurisdictional error or mala
fides are demonstrated. Issues relating to alleged coercion, ITC reversal or
refund withdrawal may be raised in appropriate proceedings after completion of
investigation.
Final
Outcome
The writ petition filed by A V Enterprises
was dismissed. The Delhi High Court declined to interfere with the
search and seizure proceedings conducted under Section 67 of the CGST Act
and permitted the GST Department to proceed with the investigation in
accordance with law. All pending applications, if any, were disposed of
accordingly.
Source Link- https://delhihighcourt.nic.in/app/showFileJudgment/PMS15092025CW138212025_155439.pdf
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