Bank account attachment for director's penalty was lifted conditionally, balancing recovery powers with separate company identity.

Attachment of a company's bank account for recovery of a director's unpaid penalty under the Tamil Nadu Value Added Tax Act was addressed by balancing the company's separate juristic status against the Revenue's power to attach monies due or becoming due to the dealer. The tax liability under the revised assessment had already been discharged, but the penalty component remained unpaid. Relief was made conditional on payment of part of the penalty, credit for the amount already recovered, and security for the balance by personal bond. The attachment was to be raised on compliance, with automatic revival if the underlying penalty order was not challenged within the stipulated time.

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Issues: Whether the attachment of the writ petitioner company's bank account to recover the unpaid penalty imposed on its director under the Tamil Nadu Value Added Tax Act, 2006 could be continued, or whether it should be raised on payment of part of the amount and furnishing of security.

Analysis: The tax liability under the revised assessment had already been discharged, but the penalty component remained unpaid and was sought to be recovered by attaching the company's bank account. The Court noted the contention that the company is a distinct juristic entity, while also noticing the Revenue's reliance on the provision enabling attachment of money due or to become due to the dealer. Without entering into the merits of the challenge to the assessment proceedings, the Court balanced the petitioner's request for relief against the Revenue's interest by directing payment of 25% of the penalty amount, crediting the sum already recovered, and securing the balance by a personal bond.

Conclusion: The attachment was not finally sustained; it was ordered to be raised on compliance with the directed payment and bond, with automatic revival if the underlying penalty order was not challenged within the stipulated time.

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