FORM GST DRC-22 - Commissioner’s provisional attachment of identified property
Qualifying proceedings have begun and the Commissioner considers attachment necessary to protect revenue.
Responsible actor: The Commissioner forms the statutory opinion and issues the written protective order. Provision: Section 83; rule 159(1),(2); notification 52/2023.
Official source and completed example
Download official blank source extract PDF Download completed fictional sample PDF
The sample is a flowed model of the prescribed fields and selected paragraphs, not an official issued PDF. Names, references and facts are fictional. It contains no signature, stamp, DSC or simulated approval.
Current law checked 21 October 2026. Fictional September/October 2026 alternative branches, unsigned and unissued; source 2022 form plus identified later amendments.
Worked facts and completed entries
Independent provisional-attachment branch: section 67 inspection proceedings under Chapter XIV begin 15 September 2026. The Commissioner records invoice/ledger evidence indicating a possible 120000 tax exposure and contemporaneous attempted disposal of the purported company storage unit, explaining why protection of revenue is considered necessary. On 28 September a written DRC-22 provisionally attaches that identified unit. This is protective, before a final demand, and not itself recovery or final tax adjudication.
Reference, authority and person
| Reference / date | ILLUSTRATION-DRC22-P-2026-0928 /28 September 2026 |
|---|---|
| To | Property Registering Authority, Illustration Bengaluru Office |
| Registered person / GSTIN | Aster Learning Supplies Private Limited (fictional) /29AABCA0000A1ZT |
| Principal place / PAN | 12 Learning Park, Bengaluru, Karnataka 560001 (fictional) /AABCA0000A (fictional) |
| Section 122(1A) non-registered-person alternative | Not selected; no Aadhaar number is invented |
| Proceeding | Section 67, Chapter XIV, initiated 15 September 2026 |
Selected immovable-property particulars
| Property ID | ILLUSTRATION-UNIT-EDU-S12 |
|---|---|
| Building / floor / premises | Unit EDU-S12 /Ground /Illustration Storage Annex |
| Road / locality / district | Learning Park Road /Learning Park /Bengaluru Urban |
| State / PIN | Karnataka /560001 |
| Estimated value / exposure | 150000 /120000; provisional exposure, not a final demand |
Opinion, attachment and restriction
The fictional written reasons identify suspected invoice/credit transactions and the attempted disposal of the specifically identified storage unit. The Commissioner considers this property provisionally attachable to protect the stated exposure and prohibits disposal without prior permission. Bank account, vehicle and other-property alternatives are not selected; no bank debit freeze is imposed. Actual ownership, proportionality and necessity remain essential; the order does not establish final tax liability.
Current mandatory cessation paragraph
This order shall cease to have effect on the date the Commissioner issues DRC-23 or on expiry of one year from 28 September 2026, whichever is earlier. The rule 159(2) encumbrance also ends on that earlier event; an indefinite freeze pending a new letter is not asserted.
Commissioner and copies
| Name / designation | R. Kavya /Commissioner, Bengaluru (fictional) |
|---|---|
| Signature / date | Not executed /28 September 2026 |
| Copies | Person whose property is attached; relevant registering authority |
| Objection route | FORM GST DRC-22A under rule 159(5), with supporting ownership/other evidence and hearing |
How this form moves the matter forward
- Confirm a qualifying proceeding, actual belonging/ownership and the Commissioner’s reasoned necessity opinion.
- Identify the property precisely, communicate the written order and copy it to the affected person/authority.
- Consider DRC-22A objections with hearing and release when appropriate; record the one-year/earlier-release cessation.
Evidence supporting these entries
- Proceeding initiation and underlying exposure evidence
- Commissioner’s actual written reasons, ownership/value and disposal-risk material
- Order service/copies, objection/hearing and encumbrance/release record
Additional primary authority: Official CGST Act as on 11 June 2026, sections 78–80 PDF pages 73–75, section 83 PDF page 75, section 88 PDF pages 76–77, section 122(1)(vii).
Additional primary authority: Current rules 143–160, PDF pages 350–357; 144(5) payment from auction versus 147(12) payment from notice;159 current objection/release/expiry provisions.
Additional primary authority: Notification 52/2023-Central Tax,26 October 2023:paragraph 4 PDF page 1 amends rule 159(2); paragraph 9 PDF page 4 inserts DRC-22 automatic-expiry paragraph.
Period and legal consequences
The January 2022 blank lacks the October 2023 automatic-expiry paragraph. The official source extract includes the amending text and the model applies it. Current rule 159(5) uses DRC-22A and does not retain the old seven-day objection wording. Section 83 is confined to qualifying proceedings and property belonging to the identified statutory person, not every connected person’s assets.
Primary source and exact locator
Official notified form source: PDF pages 452-453; printed pages 446-447.
CGST Act and government-hosted Act and Rules compilation - Section 83; rule 159(1),(2); notification 52/2023. Source and example revision: 21 October 2026.
Questions answered by this example
Who prepares or issues this form?
The Commissioner forms the statutory opinion and issues the written protective order. Qualifying proceedings have begun and the Commissioner considers attachment necessary to protect revenue.
Can this sample be filed or treated as an issued document?
No. It is a completed fictional teaching example. Use the notified form and the authenticated portal/proceeding record for an actual matter. The example contains no executed signature or official approval.
What must reconcile before the next step?
Proceeding initiation and underlying exposure evidence; Commissioner’s actual written reasons, ownership/value and disposal-risk material; Order service/copies, objection/hearing and encumbrance/release record.