Section 67 of CGST Act: Power of Inspection, Search and Seizure
Section 67 of the Central Goods and Services Tax Act, 2017 gives specified senior GST officers power to authorise inspection and, where the statutory conditions are met, to conduct or authorise search and seizure of goods, documents, books and other things.
Updated: 15 September 2026
Meaning and scope of Section 67
The CGST Act does not separately define the expressions "inspection", "search" and "seizure" in Section 2. In practical terms, inspection is a statutory examination of a place of business or other specified place; search is a more intrusive exercise directed at locating goods, documents, books or things believed to be secreted; and seizure involves taking lawful control or possession of the material covered by the provision.
Section 67 forms part of Chapter XIV of the CGST Act, dealing with inspection, search, seizure and arrest. Its powers should be read with the applicable provisions of the CGST Rules, particularly Rule 139 for authorisation, seizure and prohibition orders and Rule 140 for provisional release of seized goods.
Inspection under Section 67(1)
A proper officer not below the rank of Joint Commissioner may authorise another central tax officer in writing to inspect specified places when the officer has reasons to believe that the statutory circumstances exist. These include suppression of supply transactions or stock, excess input tax credit, contravention intended to evade tax, or specified conduct involving transporters, warehouse owners or godown operators that is likely to facilitate tax evasion.
The written authorisation mechanism is important because Rule 139(1) prescribes FORM GST INS-01 for inspection or search authorisation.
Search and seizure under Section 67(2)
Search and seizure may follow an inspection, but Section 67(2) also permits action "otherwise" where the prescribed authority has reasons to believe that goods liable to confiscation, or documents, books or things useful or relevant to proceedings under the Act, are secreted in any place.
If physical seizure of goods is not practicable, the officer may prohibit the owner or custodian from removing, parting with or otherwise dealing with the goods without prior permission. Rule 139 prescribes FORM GST INS-02 for seizure and FORM GST INS-03 for an order of prohibition where seizure is not practicable.
Documents, seized goods and important safeguards
| Provision | Practical effect |
|---|---|
| Section 67(3) | Documents, books or things not relied upon for issue of notice are to be returned within the statutory period stated in the provision. |
| Section 67(5) | A person from whose custody documents are seized is generally entitled to make copies or take extracts in the presence of an authorised officer, subject to the investigation-related exception in the provision. |
| Section 67(6) | Seized goods may be released provisionally on the prescribed bond and security or on payment of the applicable tax, interest and penalty, as the case may be. |
| Section 67(7) | If notice concerning seized goods is not given within six months, the goods are to be returned, subject to the statutory power to extend the period for sufficient cause by up to a further six months. |
| Section 67(8)-(9) | Specified perishable, hazardous, depreciating or storage-sensitive goods may be disposed of in the prescribed manner, with an inventory prepared as required. |
Rule 139 and Rule 140 of the CGST Rules
Rule 139 operationalises inspection, search and seizure. It deals with written authorisation, the seizure order, custody of seized goods, prohibition where seizure is impracticable, and preparation of an inventory. Rule 140 deals with provisional release of seized goods. Under Rule 140, provisional release is linked to a bond in FORM GST INS-04 and prescribed security.
Common forms connected with Section 67
- GST INS-01: Authorisation for inspection or search.
- GST INS-02: Order of seizure.
- GST INS-03: Order of prohibition where seizure is not practicable.
- GST INS-04: Bond for provisional release of seized goods under Rule 140.
Criminal procedure reference in Section 67(10)
The current central text of Section 67(10) continues to refer expressly to the Code of Criminal Procedure, 1973 and section 165(5) of that Code. The Bharatiya Nagarik Suraksha Sanhita, 2023 has replaced the CrPC generally with effect from 1 July 2024. Because the CGST Act text itself should not be silently rewritten, the statutory text reproduced below retains the wording appearing in the current central Act. For a live search proceeding, the applicable procedural position should be checked against the current central legislation, saving and adaptation provisions, and binding judicial interpretation.
Section 67 - statutory text
(1) Where the proper officer, not below the rank of Joint Commissioner, has reasons to believe that-
(a) a taxable person has suppressed any transaction relating to supply of goods or services or both or the stock of goods in hand, or has claimed input tax credit in excess of his entitlement under this Act or has indulged in contravention of any of the provisions of this Act or the rules made thereunder to evade tax under this Act; or
(b) any person engaged in the business of transporting goods or an owner or operator of a warehouse or a godown or any other place is keeping goods which have escaped payment of tax or has kept his accounts or goods in such a manner as is likely to cause evasion of tax payable under this Act,
he may authorise in writing any other officer of central tax to inspect any places of business of the taxable person or the persons engaged in the business of transporting goods or the owner or the operator of warehouse or godown or any other place.
(2) Where the proper officer, not below the rank of Joint Commissioner, either pursuant to an inspection carried out under sub-section (1) or otherwise, has reasons to believe that any goods liable to confiscation or any documents or books or things, which in his opinion shall be useful for or relevant to any proceedings under this Act, are secreted in any place, he may authorise in writing any other officer of central tax to search and seize or may himself search and seize such goods, documents or books or things:
Provided that where it is not practicable to seize any such goods, the proper officer, or any officer authorised by him, may serve on the owner or the custodian of the goods an order that he shall not remove, part with, or otherwise deal with the goods except with the previous permission of such officer:
Provided further that the documents or books or things so seized shall be retained by such officer only for so long as may be necessary for their examination and for any inquiry or proceedings under this Act.
(3) The documents, books or things referred to in sub-section (2) or any other documents, books or things produced by a taxable person or any other person, which have not been relied upon for the issue of notice under this Act or the rules made thereunder, shall be returned to such person within a period not exceeding thirty days of the issue of the said notice.
(4) The officer authorised under sub-section (2) shall have the power to seal or break open the door of any premises or to break open any almirah, electronic devices, box, receptacle in which any goods, accounts, registers or documents of the person are suspected to be concealed, where access to such premises, almirah, electronic devices, box or receptacle is denied.
(5) The person from whose custody any documents are seized under sub-section (2) shall be entitled to make copies thereof or take extracts therefrom in the presence of an authorised officer at such place and time as such officer may indicate in this behalf except where making such copies or taking such extracts may, in the opinion of the proper officer, prejudicially affect the investigation.
(6) The goods so seized under sub-section (2) shall be released, on a provisional basis, upon execution of a bond and furnishing of a security, in such manner and of such quantum, respectively, as may be prescribed or on payment of applicable tax, interest and penalty payable, as the case may be.
(7) Where any goods are seized under sub-section (2) and no notice in respect thereof is given within six months of the seizure of the goods, the goods shall be returned to the person from whose possession they were seized:
Provided that the period of six months may, on sufficient cause being shown, be extended by the proper officer for a further period not exceeding six months.
(8) The Government may, having regard to the perishable or hazardous nature of any goods, depreciation in the value of the goods with the passage of time, constraints of storage space for the goods or any other relevant considerations, by notification, specify the goods or class of goods which shall, as soon as may be after its seizure under sub-section (2), be disposed of by the proper officer in such manner as may be prescribed.
(9) Where any goods, being goods specified under sub-section (8), have been seized by a proper officer, or any officer authorised by him under sub-section (2), he shall prepare an inventory of such goods in such manner as may be prescribed.
(10) The provisions of the Code of Criminal Procedure, 1973, relating to search and seizure, shall, so far as may be, apply to search and seizure under this section subject to the modification that sub-section (5) of section 165 of the said Code shall have effect as if for the word "Magistrate", wherever it occurs, the word "Commissioner" were substituted.
(11) Where the proper officer has reasons to believe that any person has evaded or is attempting to evade the payment of any tax, he may, for reasons to be recorded in writing, seize the accounts, registers or documents of such person produced before him and shall grant a receipt for the same, and shall retain the same for so long as may be necessary in connection with any proceedings under this Act or the rules made thereunder for prosecution.
(12) The Commissioner or an officer authorised by him may cause purchase of any goods or services or both by any person authorised by him from the business premises of any taxable person, to check the issue of tax invoices or bills of supply by such taxable person, and on return of goods so purchased by such officer, such taxable person or any person in charge of the business premises shall refund the amount so paid towards the goods after cancelling any tax invoice or bill of supply issued earlier.
Related CGST provisions
Section 67 should be read in context with Section 68 - Inspection of goods in movement, Section 69 - Power to arrest, Section 70 - Power to summon persons to give evidence and produce documents, Section 71 - Access to business premises and Section 72 - Officers to assist proper officers.
This article is intended as a general legal information resource. Statutory provisions, rules, notifications and judicial interpretations should be checked for the facts and date relevant to a particular proceeding.