GST DRC-22A explained: objecting to a provisional attachment

Timing

The rule originally required objection within seven days of attachment. That limit was removed with effect from 1 January 2022, so an objection can be filed later. In practice, file it as soon as possible, because every day of a frozen account hurts the business.

Grounds to consider

Focus on the grounds that apply to your case. Listing every possible objection weakens the strong ones. Where the account is a working capital or salary account, explain the practical impact on operations and employees with figures.

• No proceedings had been initiated under the sections that allow attachment
• The property or account does not belong to the taxable person
• The attachment exceeds the likely liability
• No tangible material shows a risk to revenue
• The account holds money of others, such as escrow or employee funds
• The liability has already been paid or secured

How to draft it

State the facts briefly, identify the DRC-22 order, and address each ground with documents: bank statements, ownership papers, returns, payment proof and a working of the likely liability. Offer alternative security, such as a bank guarantee for a reasonable amount or attachment of other property, so the officer can protect revenue without stopping operations. Ask for a personal hearing.

Outcome

After hearing you, the Commissioner may release the property by an order in DRC-23. If the objection is not decided, follow up in writing. Separately, attachment lapses after one year from the date of the order. If the objection is rejected unreasonably, legal remedies before the High Court are sometimes pursued; take advice.

Keep a record of the date of filing, the hearing date and every follow-up, since these help if further remedies are needed.

Get it handled for you

Received a notice like this? Our chartered accountants draft the reply from your records and an authorised representative follows up with the officer, so you do not have to visit the department. Call or WhatsApp +91 63677 44602, or use the form below.

This guide explains the law in general terms as of October 2026. Time limits and requirements can depend on the facts of your case and on the notice you received.