#TaxmannWebinar | Summon, Arrests, and Investigations under GST

Practical insights into GST Arrest and Summons 1

By CA Tushar Aggarwal Co Founder : Tattvam Group

Contents

• Practical aspects of Arrest 3

• Practical aspects of Summon • Payment during investigation

GST Arrest vs CrPc

Meaning of term ‘Cognizable and NonCognizable Offence Section 2 (c) of Criminal Code

 Means an offence for which, and “cognizable case” means a case in which, a police officer may, in accordance with the First Schedule or under any other law for the time being in force, arrest without warrant

Section 2 (l) of Criminal Code 02

 “non-cognizable offence” means an offence for which, and “noncognizable case” means a case in which, a police officer has no authority to arrest without warrant

Bailable and Non-bailable Offence.

Sr. No

Bailable offences:

Non-Bailable offences:

Bailable offence means an offence, which is shown as bailable in the First Schedule or which is made bailable by any other Law for the time being in force.

Non-Bailable Offence means any other offence.

Bailable offences are regarded as less grave and less serious.

Bailable offences are grave and serious offences

Under bailable offences, bail is claimed as a matter of right.

Under Non-bailable offences, bail is a matter of discretion of jurisdictional officer.

Rasik Lal v Kishore (2009) 4 SCC 446. • Right to claim bail is absolute and indefeasible • Court or the police as the case may be will be bound to release him on bail

Bail may granted as per the directions under Section 437 and 439 of CrPC.

Power of Arrest- Section 69 of C/SGST Act

Where the Commissioner has reasons to believe that a person has committed any offence specified in clause (a) or clause (b) or clause (c) or clause (d) of sub-section (1) of section 132 which is punishable under clause (i) or (ii) of sub-section (1), or sub-section (2) of the said section, he may, by order, authorise any officer of central/state tax to arrest such person

Where a person is arrested under sub-section (1) for an offence specified under subsection (5) of section 132, the officer authorised to arrest the person shall inform such person of the grounds of arrest and produce him before a Magistrate within twenty-four hours

1. Subject to the provisions of the Code of Criminal Procedure, 1973,–– (a) where a person is arrested under sub-section (1) for any offence specified under sub-section (4) of section 132, he shall be admitted to bail or in default of bail, forwarded to the custody of the Magistrate; (b) in the case of a non-cognizable and bailable offence, the Deputy Commissioner or the Assistant Commissioner shall, for the purpose of releasing an arrested person on bail or otherwise, have the same powers and be subject to the same provisions as an officer-in-charge of a police station © Tattvam Advisors, All rights reserved

Section 132, CGST: Punishment for certain offences

Whoever commits or causes to commit and retain the benefits arising out of, any of the following offences namely [Section 132 (1) (a) to (d)]a)

supplies any goods or services or both without issue of any invoice, with the intention to evade tax;

issues any invoice or bill without supply of goods or services or both, leading to wrongful availment or utilisation of input tax credit or refund of tax; 3 avails input tax credit using such invoice or bill referred to in clause (b) or fraudulently avails input tax credit without any invoice or bill; 1 collects any amount as tax but fails to pay the same to the Government beyond a period of three months from the date on which such payment becomes due. 2

c) d)

Other Offences - Section 132 (1) (e) to (i)

Evades tax or fraudulently avails input tax credit without any invoice or bill or fraudulently obtains refund and where such an offence is not covered in clauses (a) to (d);

Falsifies or substitute financial records or produces fake accounts or documents or furnishes any false information;

Obstructs or prevents any officer in the discharge of his duties;

Acquires possession of, or in any way concerns himself in transporting, removing, depositing, keeping, concealing, supplying or purchasing or in any manner deals with, any goods which he knows or has reasons to believe 3 are liable for confiscation;

Receives1or is in any way concerned with the supply of, or in any other manner deals with any supply of services which he knows or has reasons to believe are in contravention of this Act or Rules;

2 any material evidence or documents; Tampers with or destroys

Failing to supply any information required under the Act /Rules or supplies false information;

Attempts to commit or abets the commission of any of the offences mentioned in clause (a) to (k)

Section 132, CGST: Punishment for certain offences Nature of Offence

Amount Involved

Tax evaded or Input Tax Credit wrongly taken or utilized, or refund wrongly taken

Period of Maximum Imprisonment and Fine

Exceeds Rs 1 crores but upto Rs 2 crores

1 year and with fine

Exceeds Rs 2 crores but upto Rs 5 crores

3 years and with fine

Exceeds Rs 5 crores

5 years and with fine

3 Commits or abets the commission of an offence specified 1 in clause (f) or (g) or (j)

6 months or with fine or with both

2 For second or every subsequent offence u/s 132

No limit

5 years and with fine

without any specific and special reason as recorded in the order by the court the term of the imprisonment should not be less than 6 months.

All offences are noncognizable and bailable except the cases where tax evasion is more than Rs. 5 crores prosecution cannot be initiated in case the amount involved is less than one crore for first offender but penalty can be there Previous sanction commissioner would required.

of be

Section 132: Recent Amendment & impact (w.e.f. 01.01.2021)

• Section 132 being amended to make certain specific offence as cognizable and non-bailable. Such offense(s) now covers fraudulent availment of input tax without invoice or bill. 3 38TH 1GST Council Comments: This type of offence is as grave as an offence under section 132(1)(c),having equal 2 repercussions on the government revenue

• Further, it is amended to make liable person(s) who causes to commit and retains the benefit apart from the person committing the offences for the punishment. 38TH GST Council Comments: In the entire operation/fraud, the person who is the mastermind is the key person who abets or causes the commission of an offence. But, in the present scheme of GST law, stringent penal provisions are not available for such persons causing /abetting the offence.

Scope of “Reason to Believe” 3

1 2

Reason to believe- Judgements GST regime

•

‘Reason to believe’ consists of two words “reason” and “to believe”. The word “reason” means cause or justification and the word “believe” means to accept as true or to have faith in it. Therefore, there must be justification for it and belief is the result of the mental exercise based on information received. The

words “reason to believe' contemplate an objective determination based on intelligence, care and 3 deliberation involving judicial review as distinguished from a purely subjective consideration. 1 (Vimal Yashwantgiri Goswami v. State Of Gujarat - Gujarat High Court) •

The belief must be held in good faith: it cannot be merely a pretence. Reasons to believe does not mean a 2 purely subjective satisfaction. It contemplates existence of reasons on which the belief is founded and not merely a belief in the existence of reasons inducing the belief. (Daulat Samirpal Mehta V. Union of India, Bom. HC) © Tattvam Advisors, All rights reserved

Reason to believe – Judgements pre-GST regime To arrest a person as per S.69(1), “reason to believe” holds utmost importance. The aspect of reason to believe is crucial under GST as the Commissioner needs to have a ‘reason to believe’ before initiating an arrest.

Aslam Mohd. Merchant v. Competent Authority, Supreme Court observed that whenever a statute provides for ‘a reason to believe’, such reasons should either appear on the face of the notice or they must be available on the materials which had been placed before the officer making the arrest. Tata Chemicals Ltd v. Commissioner of Customs Supreme Court reiterated the requisites of ‘reason to believe’ and held that the reasons should be based on that of an honest and reasonable person on reasonable grounds and not merely on suspicion, gossip or rumour without any direct or circumstantial evidence. It was held that “Suffice it to say that these expressions have been held not to mean the subjective satisfaction of the officer concerned. Such power given to the concerned officer is not an arbitrary power and has to be exercised in accordance with the restraints imposed by law.” © Tattvam Advisors, All rights reserved

514 14

Whether “Reason to believe“ to be in writing •

It is established in many cases that tax officer must record ‘reason to believe’

•

If reasons to believe are recorded in the files, we do not think it is necessary to record those reasons in the authorization for arrest under Section 69(1) of the CGST Act. Since Section 69(1) of the CGST Act, 2017 specifically uses the words “reasons to believe”, in contrast to the words “reasons to be recorded” appearing in Section 41A(3) of Cr.P.C., we think that it is enough if the reasons are found in the file, though not disclosed in the order authorizing the arrest. (Re: P.V. Ramana Reddy) 3

•

1 Reasons to believe to be recorded in writing and communicated to the detenu and also must be there is arrest memo (Re: Vimal Yashwantgiri Goswami)

“Reason to believe“- Conclusion It is not necessary to communicate the

same

writing

person

arrested (However, the Gujarat HC in Vimal Yashwant giri suggested to put

The Commissioner should have

applied its mind and judicial review before coming to conclusion

this in writing )

The same must be in

Reason to believe must be based on some credible material

writing in files

Should not be based on just

The

grounds

are

not

mandatorily required to be

an opinion, rumor or

mentioned

probability

memo

arrest

Procedure for Prosecution under GST Law v/s Criminal Procedure Code

Particulars

Prosecution under CrPC

Prosecution CGST Act

Provision

Section 154 to Section 173 of Code for Criminal Procedure

Section 69 and Section 132 of the CGST Act.

Initiation of Prosecution

Information received by the Police Officer (FIR) for cognizable offences and Noncognizable offences under Section 154 and 155 of CrPC, respectively.

Based upon the ‘reasons to believe’ by the Commissioner that offence under Section 132 of the Act has been committed.

Who can make an Arrest

Police officer under Section 41, 41A, 43 of CrPC

Any Central Tax officer Authorised by Commissioner.

Power to release the arrested person on bail in case of bailable offences

Officer-in-charge of the Police Station

Deputy Commissioner Commissioner

Judicial Custody and Police Custody

After arrest, arrestee can be sent to Judicial custody or continue to be placed under Police custody at the discretion of Magistrate, subject to provisions of CrPC.

No concept of Police custody under GST law, after taking cognizance of the matter the magistrate either grant bail at its discretion or send the arrestee to Judicial custody.

Assistant

Rights of arrested person

Right to know the

Right to consult a

Ground of Arrest

legal practitioner

[Section 69(2) of

[Section

CGST Act]

CrPC.]

41D

Information regarding arrest and place of arrest to be given to one of his friends, relatives or other person [Section 41B of CrPC.]

Right to be taken before a Magistrate

Right to be examined by

Information regarding right

without

a Medical practitioner.

to be released on bail

within

Arresting procedure

 At the time of arrest, arresting officer must present an arresting memo. As per the guidelines of D.K. Basu v/s. State of West Bengal reported in 1997 (1) SCC 416 ‘arrest memo’ should include the following:

• Brief Facts of the case; • Details of the person arrested; • Gist of evidence against the person; • Relevant section(s) of the CGST/SGST Law or other laws attracted to the case and to the arrested person; • The grounds of the arrest must be explained to the arrested person and this fact should be recorded in the arrest memo;

• A nominated person (as per the detailed provided by arrested person) of the arrested person should be informed immediately and this fact also may be mentioned in the arrest memo; • The date and time of arrest may be mentioned in the arrest memo should be given to the person arrested under proper acknowledgement;

Types of Bails

Anticipatory Bail

Regular Bail

Default Bail

Interim Bail

Types of Bails Anticipatory Bail

Default Bail

It can be sought in anticipation of an arrest on accusation of having committed offence.

If chargesheet is not filed within 60 days by the police then arrestee is entitled to receive default bail.

Regular Bail

Interim Bail

It is granted by the court after a person has been arrested on commission of an offence, such bail provides right to be released from the police custody

It is a temporary bail granted by the Court during the pendency of any application or until Anticipatory or Regular Bail application is pending before the Court on meeting certain conditions. For ex. Interim bail may be allowed to mitigate the risk of spreading COVID disease as held in Narayan Kumar Khaitan vs UOI.

Factors Affecting grant of Bails under GST Law.

•

Gravity of Offence

•

Procedure under provisions of CrPC not followed at the time of making arrest

•

Show cause notice not issued under Section 73 and 74 of CGST Act

•

Incriminating statements by the accused.

•

Previous history of accused (repeat offender)

•

Cooperation with the investigation

•

Likeliness of hindering the ongoing investigation

•

Chances of tampering the evidence which are yet to be discovered

•

No evidence has been brought on record to make out case against the accused

•

Frivolous accusations against the accused.

•

Time spent under the custody

•

Pre-deposit of tax under default

Defenses in case of prosecution In case, a prosecution has been launched, the accused may defend the case:

By compounding.

By pleading not guilty and facing trial;

By discharging the onus of proof of absence of Mens rea for commission of the crime alleged; In a Warrant-case, by demonstrating at the state of framing of the charge by the court, that no case can be made out on the basis of the facts and documents available on record; or By filing a petition under Sec. 482 of the Cr.P.C. for quashing of the prosecution, provided merits of the case support such petition.

QUASHING PETITION UNDER SEC. 482 OF THE CR.P.C. One of the most resorted to and sought after remedy in prosecutions under GST Act, is filing of a quashing petition under Sec. 482 of the Cr.P.C. However, one has to understand that for each and every case, quashing petition under Sec.482 of the Cr.C.P.C., may not be an effective remedy. © Tattvam Advisors, All rights reserved

Adjudication before Arrest- Favorable Judgements

The case of Make My Trip (India) Pvt Ltd v. UOI, the following observations were made by the Hon’ble High Court of Delhi (Affirmed by Supreme Court)-

Presumption of guilt Power to be used with circumspection and not casually Person sought to be arrested has to be given opportunity to explain material and circumstances gathered against him

Adjudication to proceed prosecution- there must be in the first place a determination that a 1 person is "liable to a penalty", which cannot happen till there is in the first place a determination in terms of Section 72 or 73 or 73 A of the FA. Habitual evader of tax

Tools for getting ‘voluntary deposit’ during investigation.

Adjudication before Arrest- Favorable Judgements Similar view has been adopted by the following courts too: •

Madras HC in case of Jayachandran Alloys (p) Ltd v. Supritendent of GST -MAD. This judgement distinguished Telengana HC Judgement in the case of PV Ramana on the ground that there the petitioner did not challenge the availment of credit basis bogus invoices.

•

P&H High Court in the case of Akhil Krishna Maggu and Anr. Versus Deputy Director, 2019

•

Hon’ble Supreme Court in the case of C. PRADEEP Petitioner(s) VERSUS THE 1 COMMISSIONEROF GST AND CENTRAL EXCISE SELAM & ANR. Special Leave to Appeal (Crl.) No(s). 6834/2019 has passed interim order in favor of petitioner.

Adjudication before Arrest- Adverse Judgements

•

The Telangana and Andhra Pradesh HC, in the case of PV Ramana Reddy v Ferrous Enterprises Private Limited, has upheld that arrest can be made before adjudication basis the following observations:

• •

•

The objects of pre-trial arrest and detention to custody pending trial, are manifold as mentioned in Section 41 of Cr.P.C. It is not only limited to investigation by the Commissioner. to say that a prosecution can be launched only after the completion of the assessment, goes contrary to Section 132. The list of offences included in sub-Section (1) of Section 132 of CGST Act, 2017 have no co-relation to assessment. the argument that there cannot be any arrest as long as the offences are compoundable, is an argument of convenience and cannot be accepted incases of this nature. 1

SLP against the order was dismissed by Supreme Court by stating they are not inclined to interfere.

Adjudication before Arrest- Adverse Judgements

•

The Gujarat High Court, in case of Vimal Yashwantgiri Goswami v. State of Gujarat - GUJARAT

HIGH COURT has held that arrest can be made, if the Commissioner has reason to believe that the person has committed specified offences, without there being any adjudication for the assessment. •

Bharat Raj punj, M/s. Leel Electricals Limited Versus Commissioner of Central Goods and Service Tax Department, Jaipur - Rajasthan High Court has taken similar view.

•

This judgement and certain other judgements which have taken the similar view as above distinguished the facts of the case of “Make My Trip (India) Pvt. Ltd. v. Union of India” by stating that Make my trip collected amount with GST but the GST was not deposited. The amount was passed on to the hotels 1 alongwith GST after retaining commission, no effort was made by the Department to collect evidence from the hotels, as to whether, they had deposited GST with the Department.

Handling Summons Under GST Law

Tattvam Advisors Copyright@

Summon proceedings under GST

Section 70

The proper officer under this Act shall have power to summon any person

Whose attendance he considers necessary

Responsibilities of the person so summoned: [Source: CBIC FAQ’s] A person who is summoned, legally bound to attend either in person or by an authorized representative and he is bound to state the truth before the officer

Either to give evidence or

To produce a document or any other thing in any inquiry

In the same manner, as provided in the case of a civil court

Under the provisions of the Code of Civil Procedure, 1908.

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Summon proceedings under GST (Contd.)



Every such inquiry referred to in sub-section (1) shall be deemed to be a “judicial proceedings” within the meaning of section 193 and section 228 of the Indian Penal Code.

193 (IPC)

Person giving false evidence to be imprisoned for 7 years with fine

228 (IPC)

Person who offers insult or interrupts any public servant, punishable with imprisonment of 6 months with fine

Section 70 (2)

Consequences of non-appearance to summons -

Non-appearance w/o reasonable justification- prosecution u/s 174 of IPC for 1 month and fine

Absconds to avoid service of summons- prosecution u/s 172 of IPC for 1 month and fine

Non-production of relevant documents- prosecution u/s 175 of IPC for 1 month and fine

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Important aspects of Summon 01

 Meaning of Proper Officer and Jurisdiction issues - Superintendent defined to be proper officer under

Circular 3/3/2017. Any superior officer can also exercise power under Section 5(2). Superintendent (Audit) has no jurisdiction. DGGI has all India jurisdiction. summons can be issued to persons residing within the territorial jurisdiction of the proper officer but it can be extended upto 200km.

Statements – Whether admissible as evidence and can copy of evidence be obtained -

Statements before GST officers can be admissible as evidence. Record every thing post hearing

03 03

Law of retraction If a statement is subsequently found to be incorrect or was given not under proper mind or taken under coercion, should be retracted at the earliest possible

04 05

time. Can CA/advocate accompany - Judiciary divided on this issue. Practically you request officer but such request is always denied. Approach High Court.

05 Law of Cross examination - Assessee has right to cross examine the witness/ third party whose statements has been obtained and used against such person. Tattvam Advisors Copyright@

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CBIC Guidelines

Summon is to be issued as a last resort where assesses are not cooperating and this section should not be used for the top management;

04 03

Not required for senior most officers (MD, DGM, CIO etc) to be having knowledge of minute operations. They should not be summoned unless required. Entities may intimate the officers who are familiar with the records. (Gail Gas Limited – Del HC (2018))

Summons should not be issued repeatedly. As far as practicable, the statement of the accused or witness should be recorded in minimum number of appearances.

Statements should be recorded during office hours Exception could be made regarding time and place of recording statement having regard to the facts in the case.

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Statements – Whether admissible as evidence

Sec 25 and 26 of the Indian Evidence Act

A confession made by a person to the police officer is inadmissible and holds no value

Romesh Chandra Mehta (AIR 1970 SC 940) For Section 25 of Indian Evidence Act, customs officers are not police officers though they may have specific powers of them

Thereby, statements before customs officers can be admissible as evidence

Clause (b) of Section 136 of the CGST Act, 2017 provides that statement shall be relevant, only when the person, who made the statement is examined as witness before the Court and the court is of the opinion that, having regard to the circumstances of the case, the statement should be admitted in evidence in the interest of justice. statements should be immediately

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Right of silence during summons

Article 20(3)

No person accused of any offence can be compelled to be a witness against himself

Sec. 161 of CRPC

No person is bound to answer any question which exposes him to a criminal charge

NSR Krishna Prasad (1992 (57) ELT AP 568)

Padam Narain Agarwal (AIR 2009 SC 254)

PV Ramana Reddy (Tel)

Right to silence is not an offence and cannot be said to be an obstruction to the proceedings

During summons, a person is yet not ‘accused of any offence

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Payment during Investigation

Payment during Investigation Shri Nandhi Dhall Mills India (P) Ltd. vs. SIO, DGGST [2021] 127 taxmann.com 31 (Madras) Facts: • Search and investigation was carried out at the petitioner’s premises and some voluntary payments were made by the petitioner in view of the wrongly assessed GST liability. • However, the petitioner later retracted their statement on the grounds that they were forced to accept the liability and sought refund as such payments were involuntary in nature. • The revenue contended that such voluntary payments were made in pursuance of the self-assessed tax under Section 74(5) of the CGST Act and hence should be adjusted against the ultimate tax liability post the conclusion of the full-fledged Proceedings. Conclusion: The Hon’ble High Court while allowing the refund held that: • Section 74(5) is not a statutory sanction for advance tax payment, pending final determination in assessment. It is contrary to the scheme of assessment set out under Section 74. • Merely because an assessee has made a few payments as per his signed statement under stress of investigation, it cannot lead to self-ascertainment or self-assessment of tax. • Had such self-ascertainment been made, in terms of Section 74(6), there would be no further proceedings for show cause under Section 74(1), whereas in the present case both the parties at hand are fully geared towards issuing/receiving show cause notice and taking the matter forward. Tattvam Advisors Copyright

Bundl Technologies Private Limited Vs Union of India (Karnataka High Court) Facts

Observations •

The Hon’ble (Kar) HC adjudged that the “right of a refund” would be independent of the process of investigation, and two cannot be

•

linked together, consequently, allowed the writ petition and granted

The case of the Petitioner (‘Swiggy’) was taken for investigation by the DGGI on the ground that third-party service provider ‘Greenfinch’ of the Petitioner, was a non-existence entity and accordingly the ITC

the refund to Petitioner. •

application of the Petitioner which was collected under coercion

availed by the petitioner was fraudulent. •

•

It was contended that a sum of money was illegally collected under threat and coercion without the issuance of Show Cause Notice by DGGI.

•

during an investigation by the DGGI on the basis of the following

The Petitioner asserted that during the investigation, the Petitioner was forced to make a payment under the threat of arrest.

In respect of the above, the petitioner approached the HC for issuance of writ of mandamus for granting refund of the amount collected illegally.

The Karnataka HC directed the department to consider the refund

reasons: •

The Court also acknowledged the fact that Petitioner was compelled to make the payment under duress.

•

Further, Swiggy’s payment made as a goodwill gesture during an investigation cannot be taken as self-ascertained tax.

•

While referring to the judgement of Paramvir Singh Saini v. Baljit Singh and Others reported in [(2021) 1 SCC 184], which has mandated the requirement of installation of CCTV (with mic) cameras at places where interrogation takes place, the Court observed the same has not been followed.

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Direction to issue guidelines Bhumi Associate vs UOI [2021] 124 taxmann.com 429 (Gujarat) The Hon’be High Court of Gujarat directed CBIC to issue following guidelines: • No recovery in any mode be made at the time of search/inspection proceedings under Section 67 under any circumstances. • Even if the assessee comes forward to make voluntary payment by Form DRC-03, the assessee should be asked/ advised to file such Form DRC-03 on the next day after the end of search proceedings and after the officers of the visiting team have left the premises of the assessee. • Facility of filing complaint/ grievance after the end of search proceedings should be made available to the assessee if the assessee was forced to make payment in any mode during the pendency of the search proceedings.

• If complaint/ grievance is filed by assessee and officer is found to have acted in defiance of the afore-stated directions, then strict disciplinary action should be initiated against the concerned officer.

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Instruction No. 01/2022-23 No coercive actions to be taken for deposit of money during Search & Seizure The CBIC vide Instruction No. 01/2022-23 [GST-Investigation] dated May 25, 2022, regarding no coercive actions to be taken for deposit of money during Search & Seizure made following instructions to the tax personnel involved in investigations.

Voluntary tax payment before issuance of show cause notice is permissible in provisions of Section 73(5) and Section 74 (5) of the CGST Act, 2017.

The recovery of tax under Section 79 of CGST Act, 2017 to be made only after following the due legal process of issuance of notice and subsequent confirmation of demand by the issuance of adjudication order.

No recovery can be made unless the amount becomes payable in pursuance of an order passed by the adjudicating authority or otherwise becomes payable under the provisions of the CGST Act and rules made therein.

The taxpayer at any stage of the proceedings can make the payment of tax voluntarily. However, taxofficer should inform the taxpayer regarding the provisions of voluntary tax payments through DRC-03.

It has been clarified that there may not be any circumstance necessitating ‘recovery’ of tax dues during search or inspection or investigation proceedings.

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