Provisional attachment to protect revenue allows property attachment during assessment unless secured by an acceptable bank guarantee.

Provisional attachment of taxpayer property is authorised during pending assessment, reassessment of escaped income, or specified penalty proceedings with prior written approval of the Competent Authority; such attachment lapses after six months unless extended for stated reasons. Attachment may be revoked if the assessee furnishes a scheduled bank guarantee at or above fair market value, or a lesser amount if accepted by the Assessing Officer; valuation may be referred to the Valuation Officer. The Assessing Officer may invoke the guarantee to satisfy demands, apply proceeds against existing demand, and deposit any surplus in the Personal Deposit Account of the relevant commissioner.

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