Supreme Court: Disclosure of Bank Accounts Insufficient to Lift Restraints u/s 132(3); Appeal Dismissed, Funds Must Earn Interest.

The Supreme Court ruled that disclosure of bank accounts is not sufficient to lift a restraint on their operation under Section 132(3). The case involved an appellant whose bank account operations were restrained despite the accounts being disclosed in regular books. The Court clarified that the relationship between a bank and its customer is that of debtor and creditor, not trustee and beneficiary. The appeal was dismissed, but the Court directed that funds transferred to the Commissioner's account should be placed in an interest-bearing deposit. The assessment must be completed by March 31, 2008.