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Conditional release of a lien over provisionally attached fixed deposits can be granted where the outstanding revenue demand is adequately secured. A 20% deposit ordinarily supports a stay during appeal under the applicable CBDT circular; a 25% deposit, through a post-dated cheque, together with an undertaking not to transfer assets or create third-party rights, secured release of the lien. The Assessing Officer was required to lift the lien or recall the attachment and notify the bank once those conditions were met.
Conditional release of a lien over provisionally attached fixed deposits can be granted where the outstanding revenue demand is adequately secured. A 20% deposit ordinarily supports a stay during appeal under the applicable CBDT circular; a 25% deposit, through a post-dated cheque, together with an undertaking not to transfer assets or create third-party rights, secured release of the lien. The Assessing Officer was required to lift the lien or recall the attachment and notify the bank once those conditions were met.
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