Sameer Arora vs. The Commissioner Department Of CGST And Cx Delhi East & Anr.
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Cause title — parties, addresses and appearances
O R D E R % 22.07.2026
The Petitioner prays for the following substantive reliefs: “a. Issue a writ of Mandamus to the Respondent No.1 directing it to recall the communication titled Form GST DRC-22 marked F.No. GEXCOM/AE/529;2023-AE-PARTIII/7019 dated 03.12.2025; b. Issue a writ of Mandamus directing the Respondent no. 2 to de- attach the savings bank account no. 00911600003988 at HDFC Bank Ltd,27 West Avenue Road, West Punjabi Bagh, New Delhi of the Petitioner;”
Counter Affidavit has been filed by the Respondent stating as under:
“3. The attachment order, on its face, bore the GSTIN and PAN of the taxable person. A comparison of PAN: BDFPS9123M (as mentioned in the order) with the PAN of the actual account holder in the bank's own KYC records (AADPA8688H) would have immediately and irrefutably revealed the mismatch.
That Respondent No. 1 states that the attachment order dated This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 27/07/2026 at 15:41:38
2025 was directed solely against the taxable person M/s A.P. Enterprises, bearing GSTIN: 07RDFPS9123M1Z0 and PAN: BDFPS9123M, and that no direction was issued in respect of any account belonging to the Petitioner bearing PAN: AADPA8688H.
That the respondent no.1 do not have any objection if the bank account of the petitioner is released as the respondent no.1 never intended to pass any adverse order against the petitioner.
The provisional attachment order was issued exclusively against the taxable person M/s A.P. Enterprises bearing GSTIN: 07BDFPS9123M1Z0 and PAN: BDFPS9123M, against whom proceedings under the Act are pending. The account number furnished to Respondent No. 2 in the attachment order was the account number appearing against GSTIN: 07BDFPS9123M1Z0 as per the Bank Account Validation Details available on the official GST portal, which is a government-maintained public record.”
Keeping in view the aforesaid position, learned Counsel representing the Respondent submits that on 23.04.2026, instructions were issued to the HDFC bank to the effect that the attachment order is only in respect of account number 911600003988 and not with respect to the Petitioner.
Keeping in view the aforesaid position, the Respondent - HDFC Bank is directed to remove the attachment within a period of seven days unless it has been attached in lieu of any other order.
With these observations, the present Writ Petition, along with pending applications, is disposed of. ANIL KSHETARPAL, J. AMIT MAHAJAN, J. JULY 22, 2026/kp This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 27/07/2026 at 15:41:38
Reproduced from the public record of the Delhi High Court. Verify against the court's own copy before relying on it. Income tax judgments are on bharattax.net.