Provisional attachment of taxpayer property to protect revenue subject to documented reasons, notice, objection and time limits.

Provisional attachment allows the Commissioner to encumber a taxpayer's property, including bank accounts, where proceedings are pending and a documented opinion shows attachment is necessary to protect revenue. Attachments must be proportionate to estimated recoverable revenue, recorded in prescribed form, notified to authorities and the taxpayer, and subject to objections and personal hearing. Attachments lapse after one year; perishable or hazardous goods may be released on payment or sold with proceeds applied to dues. Immovable property is preferred, essential business inputs should normally not be attached, and statutory exemptions apply.

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