Section 67 CGST Act

Representing the Client or Running the Business: Delhi High Court Upholds GST Search of a Tax Advocate's Office Over an Advocate-Client Privilege Challenge

GST intelligence officers searched the office of a practising tax advocate and seized his firm's CPU after alleging he was not merely representing a gaming company under investigation but was himself a beneficiary of an offshore gambling operation generating an alleged ₹365.68 crore GST liability. The Delhi High Court dismissed the advocate's challenge to the search, holding that Section 67(2) of the CGST Act was validly invoked, that advocate-client privilege protects client communications rather than an advocate's own conduct, and that safeguards over third-party client data — not invalidation of the search — were the appropriate remedy.