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Recovery by bank account attachment under the A.P.V.A.T. Act cannot proceed without proof of service of the show-cause notices and assessment orders. The High Court found that the respondents produced no material showing service, and the asserted affixture after returned postal service was unsupported by proof. In the absence of demonstrated service, it held that the assessment orders had not been served on the petitioner, set aside the bank account attachment, and directed fresh service of the assessment orders on counsel, to be treated as service on the petitioner. The petitioner was left free to pursue statutory remedies and seek stay in accordance with law.
Recovery by bank account attachment under the A.P.V.A.T. Act cannot proceed without proof of service of the show-cause notices and assessment orders. The High Court found that the respondents produced no material showing service, and the asserted affixture after returned postal service was unsupported by proof. In the absence of demonstrated service, it held that the assessment orders had not been served on the petitioner, set aside the bank account attachment, and directed fresh service of the assessment orders on counsel, to be treated as service on the petitioner. The petitioner was left free to pursue statutory remedies and seek stay in accordance with law.
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