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Section 110(5) permits provisional attachment of bank accounts only upon strict compliance with substantive and procedural conditions, including the Commissioner's approval. Provisional attachment orders issued without that approval, consequential extensions, and debit-freeze directions unsupported by written reasons or approval are invalid. Written attachment orders made after approval, during proceedings against the concerned exporters, and recording the proper officer's reasons satisfy the statutory requirements and remain effective. Extension of a provisional attachment requires a pre-decisional hearing and recorded reasons; an extension made without notice, hearing, or reasons cannot be cured by a later hearing and must be set aside, subject to fresh action in accordance with law.
Section 110(5) permits provisional attachment of bank accounts only upon strict compliance with substantive and procedural conditions, including the Commissioner's approval. Provisional attachment orders issued without that approval, consequential extensions, and debit-freeze directions unsupported by written reasons or approval are invalid. Written attachment orders made after approval, during proceedings against the concerned exporters, and recording the proper officer's reasons satisfy the statutory requirements and remain effective. Extension of a provisional attachment requires a pre-decisional hearing and recorded reasons; an extension made without notice, hearing, or reasons cannot be cured by a later hearing and must be set aside, subject to fresh action in accordance with law.
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TaxTMI 
TaxTMI 
of 4891 
