When Observation Is Not Enough: Transition from Inspection to Search and Seizure (Part II)

| Last updated: 20 December 2025

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This article delves into the powers of search and seizure under the CGST Act, 2017, specifically Sections 67(2) to 67(5). It explains how tax authorities can move from simple inspection to more robust investigative tools when evidence suggests evasion or concealment of goods and documents. The piece also highlights the procedural safeguards and legal principles governing these actions, ensuring fairness and proportionality.

In Part I of this series, we explored Section 67(1) of the CGST Act, 2017, which outlines the inspection authority-serving as the initial and most limited step in the GST enforcement process, primarily focused on inspection and verification. We highlighted how inspections are confined to specific business premises, only conducted when there's a documented "reason to believe," and require approval from senior officials along with formal procedures. Importantly, inspections are not meant to be

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About the Author

Raj Jaggi

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CA. Raj Jaggi is a Chartered Accountant based in New Delhi, primarily practising in the field of Goods and Services Tax (GST) consultancy, litigation support, and advisory services. After being associated with the leading indirect tax firm A.K. Batra and Associates for nearly 19 years, from June 2007 to March 2026, he ... Read more

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