The petitioners challenged prolonged investigation by the Directorate General of GST Intelligence and consequential withholding of refunds. The factual background showed that investigations continued for years without issuance of show cause notices.

The Court held that indefinite investigation without crystallisation of liability is impermissible. Authorities were directed to complete investigation and pass appropriate orders within a stipulated timeframe. Continued restraint on refunds without adjudication was held to be unsustainable.