https://www.taxtmi.com/caselaws?id=470825 Provisional attachment under Section 24(3) requires a demonstrable basis to believe that the person in possession may alienate the benami property during the notice period. Cash already held by the Income Tax Department is unavailable for alienation by the assessee, so attachment cannot be sustained merely on that basis. A challenge to the issuing officer's competence cannot ordinarily be introduced for the first time on appeal where it involves unresolved factual issues, was not raised before the Adjudicating Authority, and no leave was obtained. Fresh attachment may be considered if later circumstances establish the statutory risk of alienation. en-us Tue, 02 Dec 2025 00:00:00 +0530 Mon, 10 Aug 2026 21:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470825 Provisional attachment under Section 24(3) requires a demonstrable basis to believe that the person in possession may alienate the benami property during the notice period. Cash already held by the Income Tax Department is unavailable for alienation by the assessee, so attachment cannot be sustained merely on that basis. A challenge to the issuing officer's competence cannot ordinarily be introduced for the first time on appeal where it involves unresolved factual issues, was not raised before the Adjudicating Authority, and no leave was obtained. Fresh attachment may be considered if later circumstances establish the statutory risk of alienation. Case-Laws Benami Property Tue, 02 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470825