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of <h1>Tax authority may provisionally attach taxpayer property during reassessment or penalty proceedings; bank guarantee can secure release under timelines</h1> Where, during pendency of assessment, reassessment of escaped income or certain large penalties, the tax authority may provisionally attach an assessee's property with prior higher-authority approval to protect revenue. Such attachment lapses after six months but may be extended in writing up to two years (or 60 days after assessment/reassessment order, whichever is later). Attachment must be revoked if a scheduled bank guarantee at least equal to fair market value (or a lower accepted amount) is furnished; the authority may obtain a valuation, has specified timelines to revoke on guarantee receipt, may invoke the guarantee to meet demands, and must release it when no longer required.
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