Provisional attachment of assets to secure high tax demands must be undertaken by assessing officers before assessment completion. Assessing Officers must, when creating large tax demands likely to be difficult to recover, enquire into and identify assessee assets and place sufficient assets under provisional attachment before completing assessment; if provisional attachment cannot continue post-assessment the same assets should be considered for attachment under post-assessment recovery provisions. Officers must record efforts and details in an Office Note, DDIT(Inv.)/ADIT(Inv.) should identify attachable properties in Appraisal Reports for search-and-seizure cases, and failures to follow these procedures attract accountability.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Provisional attachment of assets to secure high tax demands must be undertaken by assessing officers before assessment completion.
Assessing Officers must, when creating large tax demands likely to be difficult to recover, enquire into and identify assessee assets and place sufficient assets under provisional attachment before completing assessment; if provisional attachment cannot continue post-assessment the same assets should be considered for attachment under post-assessment recovery provisions. Officers must record efforts and details in an Office Note, DDIT(Inv.)/ADIT(Inv.) should identify attachable properties in Appraisal Reports for search-and-seizure cases, and failures to follow these procedures attract accountability.
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