High Court of Delhi18 September 2026

Puneet Batra v. Union of India

For revenue

W.P.(C) NO. 11021 OF 2025

The ruling in brief

Where department searched law firm premises under statutory authorization and seized client documents and CPU from advocate’s cabin, advocate-client privilege was held not to bar search as cabin formed part of authorized premises and privilege protected confidential client communications belonging to client rather than location, while prima facie material justified inquiry into advocate’s conduct, consequently writ petition was to be dismissed

Provisions considered

CGST S.67

Section 67 of Central Goods and Services Tax Act, 2017/Delhi Goods and Services Tax Act, 2017

This summary is for general information and is not legal advice. Read the full decision and the applicable law before relying on it.

The ruling in brief

Related rulings

Gauhati High Court11 Sept 2026

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Ankit Choudhary v. Union of India

Where authorities seized cash, along with other items, during search under section 67 but cash did not fall within permissible articles for seizure, such action was illegal and, although cash was refunded before adjudication, petitioner was entitled to interest for period of illegal withholding and respondent authorities were required to compute and pay such interest. GST: Where search under section 67 resulted in seizure of mobile phones, pen drives and a bank card, and since SCN was already issued, continued retention of seized goods was unwarranted and Investigating Officer was required to arrange immediate release of said items to petitioner

Gauhati High Court3 Sept 2026

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Where search was conducted at business premises of partnership firm under Section 67 based on FORM GST INS-01 authorization, plea that search was vitiated for want of authorization failed as valid authorization existed, statute did not require prior disclosure of reasons to taxable person, and adjudicating authority was to verify validity of authorization and records during adjudication. GST: Where department raised demand alleging misdeclaration or suppression after search and investigation found incriminating documents, absence of scrutiny proceedings under Section 61 did not invalidate consolidated demand-cum-show cause notice since search under Section 67 and investigation provided foundation, but if any demand rests solely on return scrutiny, relevant statutory compliance must be ensured and can be examined during adjudication. GST: Where petitioner received consolidated demand-cum-show cause notice invoking Section 74(1) for certain years and Section 74A(1) for another, objection to consolidation was untenable as no bar exists against a multi-year notice, but authority must determine liability and applicability of each provision separately for each financial year with attention to limitation and statutory requirements. GST: Where SCN invoked penalty provisions under both sections 74 or 74A and 122 in respect of same act or omission, such reference in notice does not violate bar against double penalty under section 75(13) at proposal stage, but authorities must ensure no double penalty is actually imposed during adjudication and imposition in compliance with statutory prohibition.…

Gauhati High Court10 Aug 2026

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Surendra Sharma v. State of Assam

Power conferred under section 67(4) can only be exercised upon initiation of search proceedings and so long search proceedings are continuing, keeping premises of petitioner sealed for last four months was illegal and against mandate of section 67(4), as power under Section 67(4) ceases to exist once search proceedings culminated with seizure of goods, documents, books or things

CGST S.67

Related rulings

Gauhati High Court11 Sept 2026

For assessee

CGST S.67

Puneet Batra v. Union of India

The ruling in brief

Provisions considered

Puneet Batra v. Union of India

The ruling in brief

Provisions considered

Read the full analysis

Ankit Choudhary v. Union of India

HD Associates v. Union of India

Surendra Sharma v. State of Assam

Read the full analysis