https://www.taxtmi.com/caselaws?id=470108 Tax recovery attachment under Sections 222 and 225 of the Income-tax Act and Rule 12 of the Second Schedule depends on an enforceable demand and the assessee being in default. Where the ITAT has conclusively resolved factual issues, the appellate order has been implemented, and the resulting demand has been paid or reduced to nil, a pending or potential departmental appeal does not justify retaining the attachment. The Tax Recovery Officer must remove the attachment in accordance with applicable jurisdictional law. Revenue may commence fresh recovery proceedings if it later succeeds and a valid demand arises. en-us Tue, 14 Oct 2025 00:00:00 +0530 Wed, 15 Jul 2026 18:59:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470108 Tax recovery attachment under Sections 222 and 225 of the Income-tax Act and Rule 12 of the Second Schedule depends on an enforceable demand and the assessee being in default. Where the ITAT has conclusively resolved factual issues, the appellate order has been implemented, and the resulting demand has been paid or reduced to nil, a pending or potential departmental appeal does not justify retaining the attachment. The Tax Recovery Officer must remove the attachment in accordance with applicable jurisdictional law. Revenue may commence fresh recovery proceedings if it later succeeds and a valid demand arises. Case-Laws Income Tax Tue, 14 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470108