Provisional attachment expiry rule ends bank account attachment after one year under the governing tax statute.

Provisional attachment of the petitioners' bank account could not continue beyond one year under the governing tax statute. The challenge was limited to the subsistence of the attachment, and the expiry of the one-year period was admitted and undisputed. On that basis, the attachment had ceased to have legal effect and could not survive in law, so the impugned order lost its force automatically.

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Issues: Whether the provisional attachment order of the petitioners' bank account had ceased to operate on expiry of one year under the governing tax statute.

Analysis: The challenge was confined to the subsistence of the provisional attachment. The statutory position relied upon was that a provisional attachment order cannot continue beyond one year from the date of the order. As the expiry of the one-year period was admitted and not disputed, the attachment could not survive in law.

Conclusion: The impugned provisional attachment order had lost its force in law, and the legal consequences were to follow automatically.

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