Provisional attachment to protect revenue requires prior approval and is limited by a statutory time and extension framework.

An Assessing Officer may provisionally attach property of an assessee to protect revenue, by a written order made in the manner provided in the Fifth Schedule, and only with the prior approval of the Chief Commissioner or Commissioner. Such order ceases after six months but the Chief Commissioner or Commissioner may record reasons in writing and extend the period by further periods so long as total extensions do not exceed two years.

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