Mandatory notice before bank-account attachment invalidates undisclosed recovery action and supports interim protection pending appeal hearing.

Section 226(3)(iii) requires that a copy of a bank-account attachment notice be forwarded to the assessee, as indicated by the mandatory term "shall". The notes state that failure to provide the notice, including through the ITBA portal, leaves the assessee unaware of the attachment and renders it invalid. Where related appeals are imminently listed, withdrawal of the attachment, release of the bank account, and temporary restraint on coercive recovery may be appropriate without prejudicing Revenue interests until the next hearing.

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Issues: Whether attachment of the assessee's bank account without forwarding a copy of the notice to the assessee under Section 226(3)(iii) was valid, and whether recovery of the disputed demand should be stayed pending the imminent hearing of the appeals.

Analysis: Section 226(3)(iii) uses the mandatory expression "shall" for forwarding a copy of the attachment notice to the assessee. The material showed that no copy of the notice was forwarded or made available through the ITBA portal, leaving the assessee unaware of the bank attachment. As the appeals were fixed for hearing shortly, release of the attachment and temporary protection from coercive recovery would not prejudice Revenue interests.

Conclusion: The bank-account attachment was invalid for non-compliance with the mandatory requirement of prior notice to the assessee. The issue was decided in favour of the assessee; the attachment notice was directed to be withdrawn, the bank account released, and coercive recovery restrained until the next hearing date.

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