Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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A second provisional attachment issued after the earlier order had expired was unsustainable where it rested on the same facts and no change in circumstances was shown. The Court held that Section 83(2) does not permit a fresh attachment on substantially identical grounds after the statutory one-year period, as this would defeat the built-in safeguard against misuse. It also held that provisional attachment is only a pre-emptive protective measure and cannot be used as a post-assessment recovery device once assessment has culminated in a final order. The petition was allowed and the attachment was quashed.
A second provisional attachment issued after the earlier order had expired was unsustainable where it rested on the same facts and no change in circumstances was shown. The Court held that Section 83(2) does not permit a fresh attachment on substantially identical grounds after the statutory one-year period, as this would defeat the built-in safeguard against misuse. It also held that provisional attachment is only a pre-emptive protective measure and cannot be used as a post-assessment recovery device once assessment has culminated in a final order. The petition was allowed and the attachment was quashed.
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