https://www.taxtmi.com/caselaws?id=338761 A garnishee notice under section 226(3) of the Income-tax Act could not be enforced against a bank where the record showed that the bank was itself a creditor and the fixed deposits were subject to a subsisting lien and set-off. The department therefore could not treat the bank as a mere holder of money for the assessee, because no enforceable liability to pay the depositor's funds over to the department was shown. In these circumstances, the recovery action was misconceived, and the notice and order under section 226(3) were held invalid and quashed. en-us Thu, 21 Jul 2016 00:00:00 +0530 Fri, 10 Feb 2017 10:28:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=338761 A garnishee notice under section 226(3) of the Income-tax Act could not be enforced against a bank where the record showed that the bank was itself a creditor and the fixed deposits were subject to a subsisting lien and set-off. The department therefore could not treat the bank as a mere holder of money for the assessee, because no enforceable liability to pay the depositor's funds over to the department was shown. In these circumstances, the recovery action was misconceived, and the notice and order under section 226(3) were held invalid and quashed. Case-Laws Income Tax Thu, 21 Jul 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=338761