Provisional attachment cannot freeze a payment aggregator's escrow funds without tangible material linking it to GST liability.
Case-Laws
GST
Provisional attachment of a payment aggregator's current and regulated escrow accounts requires an opinion based on tangible material showing that attachment is necessary to protect revenue. Vague suspicion of GST evasion by unidentified third-party online gaming merchants, without identifying the aggregator's tax liability, relevant transactions, evasion method, or statutory status, does not satisfy that threshold. Escrow funds reserved for merchant settlements are held in trust and are not the aggregator's attachable property. The High Court treated the attachment orders and continuing debit freezes as illegal and quashed them.
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