https://www.taxtmi.com/highlights?id=97582 Before invoking provisional attachment powers, authorities must form an objective opinion on tangible material demonstrating necessity to protect revenue; reliance on bank loans or hypothetical future demand is insufficient. Authorities must consider the assessee's history as a regular taxpayer when deciding on attachment. Provisional attachment is a draconian power and, consistent with principles of natural justice and applicable administrative guidance, the assessee should be afforded the opportunity to deposit a portion of the disputed demand as a minimum safeguard. The impugned attachment was set aside for lack of requisite formation of opinion and failure to permit the prescribed deposit mechanism, with a deposit direction issued. en-us Wed, 11 Mar 2026 11:42:33 +0530 Wed, 11 Mar 2026 11:42:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=97582 Before invoking provisional attachment powers, authorities must form an objective opinion on tangible material demonstrating necessity to protect revenue; reliance on bank loans or hypothetical future demand is insufficient. Authorities must consider the assessee's history as a regular taxpayer when deciding on attachment. Provisional attachment is a draconian power and, consistent with principles of natural justice and applicable administrative guidance, the assessee should be afforded the opportunity to deposit a portion of the disputed demand as a minimum safeguard. The impugned attachment was set aside for lack of requisite formation of opinion and failure to permit the prescribed deposit mechanism, with a deposit direction issued. Highlights Income Tax Wed, 11 Mar 2026 11:42:33 +0530 https://www.taxtmi.com/highlights?id=97582