JUDGMENT : Petitioners are partners of a firm trading in the name and style of ‘SR Trades’ (hereinafter referred to as ‘the Firm’). The Firm is, primarily, in the business of purchase and sale of scrap. In the month of November 2020, there was a search conducted in the business premises of the petitioners under Section 67 of the CGST Act. The 1st petitioner was also arrested and detained on the allegation of fraudulent transactions, leading to the evasion of GST on a massive scale. The registration of the Firm under the CGST/SGST Acts was also cancelled. According to the petitioners, they were thus forced to close down their business in the year 2022. Ext.P1 show cause notice was issued to the petitioners on 04.05.2023, calling upon the petitioners to show cause regarding the following:- “8.1 the Input Tax Credit of Rs. 8,59,16,757/-(Rupees Eight Crores, Fifty Nine Lakhs, Sixteen Thousand, Seven Hundred and Fifty-Seven only) availed by M/s SR Traders on the strength of fake invoices, as discussed above, should not be declared fake and inadmissible and recovered under sub-section (1) of Section 74 of the CGST Act, 2017, read with Section 20 of the IGST Act, 2017; 8.2 interest payable on 8.1 above, should not be demanded and recovered from them, under Section 50 of the CGST Act, 2017 read with Section 20 of the IGST Act, 2017; 8.3 for the said violation at 8.1, penalty should not be imposed upon them under Section 74 read along with Section 122(1)(vii) of the CGST Act, 2017 and Section 20 of the IGST Act, 2017.” The aforesaid show cause notice is pending adjudication. Through Ext.P2 series of proceedings dated 10.03.2023/13.03.2023, orders were issued by the Additional Director General, Directorate General of GST Intelligence, Kochi Zonal Unit under Section 83 of the CGST/SGST Acts, provisionally attaching certain properties belonging to the petitioners. Some of the attachment orders relate to the bank accounts of the Firm also. The Firm challenged the orders of provisional attachment by filing W.P.(C.)No.12519 of 2023. This Court, by the judgment dated 09.06.2023 (marked as Ext.P3 in the writ petition), dismissed the writ petition, leaving open the right of the Firm to avail alternative remedies, if available. A Writ Appeal was carried against Ext.P3. A Division Bench of this Court, by Ext.P4 judgment, modified the judgment of the learned Single Judge and directed as follows:- “4. This Court, by the judgment dated 09.06.2023 (marked as Ext.P3 in the writ petition), dismissed the writ petition, leaving open the right of the Firm to avail alternative remedies, if available. A Writ Appeal was carried against Ext.P3. A Division Bench of this Court, by Ext.P4 judgment, modified the judgment of the learned Single Judge and directed as follows:- “4. On a consideration of the rival submissions, we find that while it may be a fact that the value of the immovable properties attached is not sufficient to meet the demand contained in the show cause notices, we must necessarily remind ourselves that the appellant cannot be financially choked to the extent of preventing it from carrying on legitimate business activities while simultaneously defending the proceedings initiated by the respondents against him. We feel therefore that the ends of justice would require us to modify the judgment of the learned single Judge and permit the appellant to operate two of its bank account pending finalisation of the adjudication proceedings by the respondents so that the appellant can carry on its legitimate business activities even while defending the proceedings initiated against him by the respondents. Accordingly, we direct a lifting of the attachment in respect of the following two accounts pertaining to the appellant, and covered by Ext.P6 order that was impugned in this writ petition. (1) A/c.No.50200027207947, HDFE Bank, Pattambi -savings account in the name of Safeek.K; and (2)A/c.No.14120100032507, Federal Bank PTB – savings account in the name of Ali.K.M. 5. The appellant shall be permitted to operate the aforesaid accounts during the pendency of the adjudication proceedings initiated at the instance of the respondents and until the culmination thereof. Save for the above limited modification, we refrain from interfering with the judgment of the learned single Judge in all other respects.’’ On expiry of the period prescribed under Sub-section (2) of Section 83 of the CGST/SGST Acts, the petitioners addressed Ext.P5 series of communications to the 1st respondent, praying that the orders of provisional attachment may be lifted. However, the 1st respondent did not favour the petitioners with any reply and instead, proceeded to issue Ext.P6 series of orders, again provisionally attaching the properties belonging to the petitioners which were already subjected to orders of attachment through Ext.P2 series of orders. However, the 1st respondent did not favour the petitioners with any reply and instead, proceeded to issue Ext.P6 series of orders, again provisionally attaching the properties belonging to the petitioners which were already subjected to orders of attachment through Ext.P2 series of orders. The petitioners are thus before this Court, challenging Ext.P6 series of orders, principally, on the ground that the 1st respondent has no jurisdiction, whatsoever, to issue such orders after the expiry of the period prescribed in Sub-section (2) of Section 83 of the CGST/SGST Acts. 2. Sri. Mayankutty Mather, the learned Senior Counsel appearing for the petitioners, on the instructions of Adv. Nikitha Susan Paulson would vehemently contend with reference to the provisions contained in Section 83 of the CGST/SGST Acts that, an order of provisional attachment cannot extend beyond the period satisfied in Sub-section (2) of Section 83 of the CGST/SGST Acts. He contends that, if the 1st respondent is permitted to pass fresh orders of provisional attachment after the period specified in Subsection (2) of Section 83 of the CGST/SGST Acts, the same would lead to a situation where there can be no meaning in the time limit specified in Sub-section (2) of Section 83 of the CGST/SGST Acts. He submits that the language of Sub-section (2) of Section 83 of the CGST/SGST Acts does not permit any interpretation other than the interpretation that after a period of one year from the date of the first order, directing provisional attachment of properties, the order of attachment ceases to have effect and cannot be extended thereafter. It is submitted that a reading of Ext.P6 series of orders and Ext.P2 series of orders will indicate that there is not even one syllable that is different and it is thus clear that there is absolutely no application of mind by the 1st respondent and he has mechanically passed Ext.P6 series of orders, which again is illegal, even if it were to be conceded that the 1st respondent has got the authority to pass fresh orders on the expiry of the time limit specified in Sub-section (2) of Section 83 of the CGST/SGST Acts. 3. Learned Senior Counsel further submits that the wordings of Rule 159 of the CGST/SGST Rules, 2017 also indicates that there cannot be any order of provisional attachment that can continue beyond the period specified in Sub-section (2) of Section 83 of the CGST/SGST Acts. 3. Learned Senior Counsel further submits that the wordings of Rule 159 of the CGST/SGST Rules, 2017 also indicates that there cannot be any order of provisional attachment that can continue beyond the period specified in Sub-section (2) of Section 83 of the CGST/SGST Acts. It is submitted that even if the orders of provisional attachment are issued in statutory printed Form (GST DRC-22) as per Rule 159(1) of the CGST/SGST Rules, 2017, the same does not absolve the authorities from giving reasons as to why the orders are required to be issued. He relied on the judgment of the learned Single Judge of this Court in K.J. Joseph and Others v. Corporation of Cochin; 1987 KHC 483, in support of this contention. 4. Learned Senior Counsel extensively referred to the judgment of the Supreme Court in Radha Krishnan Industries v. State of Himachal Pradesh and Others; (2021) 6 SCC 771 to contend that, the power of provisional attachment is a drastic power and the provisions being draconian in nature, require strict interpretation and unless this Court were to find that there was a statutory authority to order an attachment beyond the time specified in Sub-section (2) of Section 83 of the CGST/SGST Acts, it must be held that Ext.P6 series of orders are without jurisdiction and contrary to the provisions of Section 83 of the CGST/SGST Acts. Learned Senior Counsel also referred to the judgment of a learned Single Judge of the Calcutta High Court in Amazonite Steel Pvt. Ltd v. Union of India; 2020 SCC OnLine Cal 3279, in support of his contention that Ext.P6 series of orders, being not different in content from Ext.P2 series of orders, would have to be set aside on that ground alone. Learned Senior Counsel submits that though the Calcutta High Court had conceded the power of the authorities to pass a fresh order after the expiry of the initial period prescribed in Sub-section (2) of Section 83 of the CGST/SGST Acts, the said judgment did not consider the provisions of Rule 159 of the CGST/SGST Rules or to the analogous provisions in Section 281B of the Income Tax Act, 1961, where again the time limit has been set for the period for which orders of provisional attachment would continue. It is submitted that though the provisions of Section 281B of the Income Tax Act contemplate an extension after the initial period of attachment, there is no provision in the CGST/SGST Acts which enables the extension of the period of attachment and on analysis of the wordings used in Sub-section (2) of Section 83 of the CGST/SGST Acts and the provisions of Rule 159 of the CGST/SGST Rules, 2017, it can only be held that the lawmakers did not intend that any order of provisional attachment under Section 83 of the CGST/SGST Acts would in any case extend beyond the period specified in Subsection (2) of Section 83 of the CGST/SGST Acts. Learned Senior Counsel would also submit that Rule 159 of the CGST/SGST Rules, 2017 was amended with effect from 26.10.2023 and that the words incorporated by way of amendment would further advance the case of the petitioner that there can be no attachment beyond the period specified in Sub-section (2) of Section 83 of the CGST/SGST Acts. 5. Sri. Sreelal N. Warrier, the learned Senior Standing Counsel appearing for the respondents would refer to the show cause notice issued to the petitioners to contend that there are very serious allegations against the petitioners. It is submitted that the amount of revenue involved is also huge as can be seen from Ext.P1 show cause notice. It is submitted that the provisions of Section 83 of the CGST/SGST Acts are incorporated to ensure that the revenue is protected. It is submitted that the intention behind the CGST/SGST Acts and especially, Section 83 of the Act was to ensure that rightful tax due to the exchequer is collected and persons like the petitioners, who indulge in fraudulent activities to defeat the exchequer of rightful dues are dealt with sternly and the amount due from them is recovered by proceeding against their properties. In other words, it is submitted that, in the facts and circumstances of the case, the only way to protect the revenue was to continue with the attachment of the properties of the petitioners, pending adjudication. It is submitted that, even if all the properties belonging to the petitioners are available to be proceeded against, considering the amount of revenue involved in this case, it is unlikely that the recovery will be effected even by selling all the properties which are the subject matter of the provisional attachment. 6. It is submitted that, even if all the properties belonging to the petitioners are available to be proceeded against, considering the amount of revenue involved in this case, it is unlikely that the recovery will be effected even by selling all the properties which are the subject matter of the provisional attachment. 6. Learned Senior Standing Counsel would also submit that the argument raised on behalf of the petitioners that there is nothing in Section 83 of the CGST/SGST Acts, which would enable the issuance of fresh order, is absolutely untenable. It is submitted that when the Court is considering a provision akin to Section 83 of the CGST/SGST Acts and when the intention behind the incorporation of such a provision is evident, the Court must lean in favour of an interpretation that would effectuate the intention of the Parliament and any other interpretation which would defeat the intention of the Parliament must be avoided. Learned Senior Standing Counsel also referred to a Division Bench judgment of the Gujarat High Court in Shrimati Priti W/o. Anil Amrutlal Gandhi v. State of Gujarat Thro’ Assistant Commissioner & 1; 2011 SCC OnLine Guj 1869 to contend that a contention similar to the contention taken in this writ petition had been rejected by the Gujarat High Court while considering the analogous provisions in Section 45 of the Gujarat Value Added Tax Act. It is submitted that the Court had categorically held that there is nothing in the provision under consideration (in that case) which would indicate that a fresh order of attachment could not be passed after the expiry of the period prescribed in the provision in question. Learned Senior Standing Counsel further submits that though the provisions of Section 83 of the CGST/SGST Acts were extensively considered by the Supreme Court in Radha Krishnan Industries (supra), the Supreme Court did not render a finding that no fresh order could be passed after the expiry of the period specified in Sub-section (2) of Section 83 of the CGST/SGST Acts and only indicated the circumstances under which an order of provisional attachment could be made with reference to the provisions of Section 83 of the CGST/SGST Acts. It is submitted that the finding of the Supreme Court that Section 83 of the CGST/SGST is drastic and draconian in nature was only with regard to the attachment of bank accounts and not to the attachment of immovable properties. It is submitted that no prejudice, whatsoever, will be caused to the petitioners if the immovable properties which are the subject matter of Ext.P6 series of orders are continued in attachment, pending adjudication of Ext.P1 show cause notice. It is submitted that the amendment to Section 83(1) after the judgment of the Supreme Court in Radha Krishnan Industries (supra) makes it clear that the provisional attachment can continue even after orders are issued. It is submitted that any provision limiting the power of attachment must be strictly construed. It is submitted that Section 83(2) is to be interpreted as a proviso which cannot control or defeat the main provision. He relied on the judgment of the Calcutta High Court in Amazonite Steel Pvt. Ltd (supra) to contend that the Calcutta High Court has considered an identical issue and has held that there is nothing in Section 83(2) to indicate that a fresh order cannot be issued after the expiry of the period mentioned in that provision. 7. Having heard the learned Senior Counsel appearing for the petitioners and the learned Senior Standing Counsel appearing for the respondents, I am of the view that the petitioners are entitled to succeed. The facts are not in dispute. Certain proceedings have been initiated against the petitioners invoking Section 74 of the CGST/SGST Acts. Therefore, going by the provisions contained in Section 83 of the CGST/SGST Acts, the competent authority has the power to provisionally attach the properties. The provisions of Section 83 of the CGST/SGST Acts prior to its amendment with effect from 1.1.2022 read as follows:- “83. Provisional attachment to protect revenue in certain cases.- (1) Where during the pendency of any proceedings under section 62 or section 63 or section 64 or section 67 or section 73 or section 74, the Commissioner is of the opinion that for the purpose of protecting the interest of the Government revenue, it is necessary so to do, he may, by order in writing attach provisionally any property, including bank account, belonging to the taxable person in such manner as may be prescribed. (2) Every such provisional attachment shall cease to have effect after the expiry of a period of one year from the date of the order made under sub-section (1).” The provisions of Section 83 of the CGST/SGST Act were amended with effect from 1.1.2022 and now read as follows:- “83. Provisional attachment to protect revenue in certain cases.- (1) Where, after the initiation of any proceeding under Chapter XII, Chapter XIV or Chapter XV, the Commissioner is of the opinion that for the purpose of protecting the interest of the Government revenue it is necessary so to do, he may, by order in writing, attach provisionally, any property, including bank account, belonging to the taxable person or any person specified in sub-section (1A) of section 122, in such manner as may be prescribed. (2) Every such provisional attachment shall cease to have effect after the expiry of a period of one year from the date of the order made under sub-section (1).” I thought it necessary to refer to the unamended provisions of Section 83 considering the fact that considerable reliance was placed by the learned Senior Counsel appearing for the petitioners on the judgment of the Supreme Court in Radha Krishnan Industries (supra) which dealt with the provisions of Section 83 as it stood prior to its amendment with effect from 1.1.2022. However, the amendments have no bearing on the precedential value of the judgment of the Supreme Court in Radha Krishnan Industries (supra) for the reason that in substance there is no difference in the provision. The Supreme Court, after referring to the provisions of Section 83 of the CGST/SGST Acts prior to its amendment with effect from 1.1.2022, held as follows:- “40. The marginal note to Section 83 provides some indication of parliamentary intent. Section 83 provides for “provisional attachment to protect revenue in certain cases”. The first point to note is that the attachment is provisional—provisional in the sense that it is in aid of something else. The second point to note is that the purpose is to protect the revenue. The third point is the expression “in certain cases” which shows that in order to effect a provisional attachment, the conditions which have been spelt out in the statute must be fulfilled. Marginal notes, it is well-settled, do not control a statutory provision but provide some guidance in regard to content. The third point is the expression “in certain cases” which shows that in order to effect a provisional attachment, the conditions which have been spelt out in the statute must be fulfilled. Marginal notes, it is well-settled, do not control a statutory provision but provide some guidance in regard to content. Put differently, a marginal note indicates the drift of the provision. With these prefatory comments, the judgment must turn to the essential task of statutory construction. The language of the statute has to be interpreted bearing in mind that it is a taxing statute which comes up for interpretation. The provision must be construed on its plain terms. Equally, in interpreting the statute, we must have regard to the purpose underlying the provision. An interpretation which effectuates the purpose must be preferred particularly when it is supported by the plain meaning of the words used” It is clear from the law laid down in Radha Krishnan Industries (supra) that while interpreting a taxing statute, the provisions must be construed on its plain terms and the Court must have regard to the purpose underlying the provision and an interpretation which effectuates the purpose must be preferred particularly when it is supported by the plain meaning of the words used. As can be seen from the provision of Section 83(2) of the CGST/SGST Acts, an order of provisional attachment under Sub section (1) of Section 83 will cease to have effect after the expiry of the period of one year from the date of the order made under Subsection (1). As distinct from the provisions of Section 281B of the Income Tax Act, 1961, the provisions of Section 83(2) of the CGST/SGST Acts do not even provide for the extension of the period of provisional attachment. Therefore, it must be held that on the plain meaning of the words used in Sub-section (2) of Section 83 of the CGST/SGST Acts, an attachment cannot extend beyond the period specified in Sub-section (2) of Section 83. In paragraph 42 of Radha Krishnan Industries (supra) it was observed:- “42. Therefore, it must be held that on the plain meaning of the words used in Sub-section (2) of Section 83 of the CGST/SGST Acts, an attachment cannot extend beyond the period specified in Sub-section (2) of Section 83. In paragraph 42 of Radha Krishnan Industries (supra) it was observed:- “42. Under sub-section (2) of Section 83, a provisional attachment ceases to have effect upon the expiry of a period of one year of the order being passed under subsection (1).....” The contention of the learned Senior Standing Counsel that after the amendment the order can continue even after final orders are passed has no bearing on the question as to whether such an order can continue beyond the period specified in Section 83(2). In other words, even if this contention is to be accepted, the order will cease to have effect after the period specified in Section 83(2). 8. The learned Senior Counsel appearing for the petitioners is also right in contending that the provisions of Rule 159 of the CGST Rules, 2017 also indicate that the provisional attachment cannot extend beyond the period specified in Subsection (2) of Section 83. The rule-making authority considered the time limit to be mandatory. The words “or on expiry of a period of one year from the date of issuance of order under sub-rule (1), whichever is earlier” were inserted in Sub-rule (2) of Rule 159, by amendment, with effect from 26.10.2023. Rule 159 (to the extent relevant) after its amendment w.e.f 26.10.2023 reads thus:- “Rule 159. Provisional attachment of property. The words “or on expiry of a period of one year from the date of issuance of order under sub-rule (1), whichever is earlier” were inserted in Sub-rule (2) of Rule 159, by amendment, with effect from 26.10.2023. Rule 159 (to the extent relevant) after its amendment w.e.f 26.10.2023 reads thus:- “Rule 159. Provisional attachment of property. - (1) xxx xxx xxx (2) The Commissioner shall send a copy of the order of attachment in form GST DRC-22 to the concerned Revenue Authority or Transport Authority or any such Authority to place encumbrance on the said movable or immovable property, which shall be removed only on the written instructions from the Commissioner to that effect or on expiry of a period of one year from the date of issuance of order under sub-rule (1), whichever is earlier, and a copy of such order shall also be sent to the person whose property is being attached under section 83” Therefore, it is clear that the provisions of Section 83(2) read with the provisions of Rule 159 of the CGST Rules, 2017 indicate beyond doubt that a provisional attachment under sub-section (2) of Section 83 cannot extend beyond a period of one year from the date on which it was first made. To accept the contention of the Revenue in this case would be to do violence to the language of the statute and permit the Revenue to keep on issuing repeated orders of provisional attachment which would mean that the provisional attachment can continue for as long as the Revenue decides that it must continue. This, obviously, was not the intention of the legislature, for had the intention been different, the provisions of Sub-section (2) of Section 83 would have been worded differently. The judgment in Radha Krishnan Industries (supra) is also the authority for the proposition that the provisions of Section 83 are draconian in nature (See paragraphs 49 & 50 of the report). The provisions, therefore, require strict interpretation. 9. The learned Senior Standing Counsel appearing for the Revenue may be justified in contending that it is necessary that the law is equipped to deal with persons who engage in fraudulent activities to avoid the payment of tax legally due from them or engage in activities which would result in wrongful loss of revenue to the State Exchequer. 9. The learned Senior Standing Counsel appearing for the Revenue may be justified in contending that it is necessary that the law is equipped to deal with persons who engage in fraudulent activities to avoid the payment of tax legally due from them or engage in activities which would result in wrongful loss of revenue to the State Exchequer. However, it is not the duty of the Court to change the plain meaning of the statute and concede to the Revenue a right or authority which was never in the contemplation of the Legislature. Policy making is not the duty of the Court and the Court must interpret the law as it finds it. In C.A. Abraham v. ITO, (1961) 41 ITR 425 , the Supreme Court held:- “6. The Legislature has expressly enacted that the provisions of Chapter IV shall apply to the assessment of a business carried on by a firm even after discontinuance of its business, and if the process of assessment includes taking steps for imposing penalties, the plea that the Legislature has inadvertently left a lacuna in the Act stands refuted. It is implicit in the contention of the appellant that it is open to the partners of a firm guilty of conduct exposing them to penalty under Section 28 to evade penalty by the simple expedient of discontinuing the firm. This plea may be accepted only if the court is compelled, in view of unambiguous language, to hold that such was the intention of the Legislature. Here the language used does not even tend to such an interpretation. In interpreting a fiscal statute, the court cannot proceed to make good deficiencies if there be any : the court must interpret the statute as it stands and in case of doubt in a manner favourable to the taxpayer. But where as in the present case, by the use of words capable of comprehensive import, provision is made for imposing liability for penalty upon taxpayers guilty of fraud, gross negligence or contumacious conduct, an assumption that the words were used in a restricted sense so as to defeat the avowed object of the Legislature qua a certain class will not be lightly made. (Emphasis is mine) In considering this issue, the following observations of the House of Lords in its opinion in IRC v. Wolfson; (1949) 1 All.E.R 865 are relevant:- “It was urged that the construction that I favour leaves an easy loophole through which the evasive taxpayer may find escape. That may be so; but I will repeat what has been said before. It is not the function of a court of law to give to words a strained and unnatural meaning because only thus will a taxing section apply to a transaction which, had the Legislature thought of it, would have been covered by appropriate words. It is the duty of the Court to give to the words of this Sub-section their reasonable meaning and I must decline on any ground of policy to give to them a meaning which, with all respect to the dissentient Lord Justice, I regard as little short of extravagant. It cannot even be urged that unless this meaning is given to the Section it can have no operation. On the contrary, given its natural meaning it will bring within the area of taxation a number of cases in which by a familiar device tax had formerly been avoided.” The Supreme Court, in CIT v. Jayantilal Amratlal; 1967 SCC OnLine SC 219, while interpreting Sec 16(1)(c) of the Income Tax Act, referred to the above observations in Wolfson (supra) with approval. Several years later the House of Lords in its opinion in Ransom (Inspector of Taxes) v. Higgs; (1974) 3 All.E.R. 949 observed:- “.....It may seem hard that a cunningly advised taxpayer should be able to avoid what appears to be his equitable share of the general fiscal burden and cast it on the shoulders of his fellow citizens. But for the courts to try to stretch the law to meet hard cases (whether the hardship appears to bear on the individual taxpayer or on the general body of taxpayers as represented by the Inland Revenue) is not merely to make bad law but to run the risk of subverting the rule of law itself. Disagreeable as it may seem that some taxpayers should escape what might appear to be their fair share of the general burden of national expenditure, it would be far more disagreeable to substitute the rule of caprice for that of law. Disagreeable as it may seem that some taxpayers should escape what might appear to be their fair share of the general burden of national expenditure, it would be far more disagreeable to substitute the rule of caprice for that of law. The most famous warning in the history of our fiscal law is constituted by Rex v. Hampden, Ship-Money Case (1637) 3 St.Tr. 826. It could be strongly argued that it was contrary to fiscal equity that the financial burden of providing warships (or their money equivalent) for the defence of the whole realm should fall exclusively on the inhabitants of maritime towns and districts, to the exoneration of inland citizens: yet such, it seems, was the law of the land; and the judges who appear to have stretched that law have not escaped the censure of history. So I think that counsel for the taxpayers was justified, when frankly admitting that your Lordships were concerned with unmeritorious tax avoidance schemes, in drawing attention to Inland Revenue Commissioners v. Duke of Westminster [1936] A.C. 1. There Lord Tomlin (p. 19) cited Coke (4 Inst. 41), on the danger of “substituting the incertain and crooked cord of discretion' for ‘the golden and streight metwand of the law.’” And Lord Russell of Killowen (p. 24) cited Lord Cairns (Partington v. Attorney–General (1869) L.R. 4 H.L. 100, 122): “If the person sought to be taxed comes within the letter of the law he must be taxed, however great the hardship may appear to the judicial mind to be. On the other hand, if the Crown, seeking to recover the tax, cannot bring the subject within the letter of the law, the subject is free, however apparently within the spirit of the law the case might otherwise appear to be” — although I do not take either great judge as meaning that the “letter” of the law was to be interpreted in exclusion of the resolutions in Heydon's Case (1584) 3 Co.Rep. 7a ……..” (emphasis is mine) In Vodafone International Holdings BV v. Union of India; (2012) 6 SCC 613 , the Supreme Court considered whether the sale of certain shares by HTIL to Vodafone would amount to a transfer of a capital asset within the meaning of Section 2(14) of the Income Tax Act. 7a ……..” (emphasis is mine) In Vodafone International Holdings BV v. Union of India; (2012) 6 SCC 613 , the Supreme Court considered whether the sale of certain shares by HTIL to Vodafone would amount to a transfer of a capital asset within the meaning of Section 2(14) of the Income Tax Act. In interpreting the expression “source of income in India” used in Section 9(1)(i), the Court approved the above observations in Ransom (supra). These decisions are clear authority for the proposition that the Courts will not step in and supply words or give the provisions of a statute a different meaning even if they feel that such interpretation may be necessary in the larger public interest. In this view of the matter, I am in respectful disagreement with the view of the Calcutta High Court in Amazonite Steel Pvt. Ltd (supra) and the judgment of the Gujarat High Court in Shrimati Priti (supra) where an almost identical provision in the Gujarat Sales Tax Act was interpreted. 10. In view of the above findings, it is not necessary to consider the contention that Ext.P6 series of orders also suffers from the vice of non-application of mind and is a verbatim reproduction of Ext.P2 series of orders. The writ petition is allowed. Ext.P6 series of orders will stand quashed. It is declared that the provisions of Section 83 of the CGST/SGST Acts do not contemplate or authorise the issuance of a fresh order of attachment after the period specified in Section 83(2) of the CGST/SGST Acts.