Prohibitory order issuance must follow interview and payment reconciliation to prevent wrongful bank attachments.

Issuance of prohibitory orders against an assessee's bankers requires strict adherence to existing procedure: officers must interview the assessee, ascertain facts, and reconcile payments before taking coercive action to prevent wrongful attachment where payment has already been made; these procedural instructions must be communicated to all officers to ensure scrutiny and avoid recurrence.

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