2013 (10) TMI 108

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....espondent : R.K. Patel. ORDER:- PER : Akil Kureshi The applicants-original respondents have filed present Civil Application seeking recall of our order dated April 16, 2013 passed in Special Civil Application No.16617 of 2012. 2. This prayer is made primarily on the ground that in such order, we had recorded that the order of attachment under Section 281B(2) of the Income-Tax Act, 1961....

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.... had provided that :      "After hearing the learned counsel for the parties, we notice that the impugned order of attachment of the bank account of the petitioner No.910020050265257 of the Axis Bank, Opposite GEB, Near Pizza Hut, Race Course Circle, Vadodara was passed on 26.7.2012. In terms of sub-section (2) of section 281B, such order would have a life of six months from....

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.... having lapsed with afflux of time, the petitioner would be free to operate the said bank account." 4. What third proviso to Section 281B(2) of the Act provides is for exclusion of the period of two years provided in first proviso, during which the proceedings of assessment are stayed by any Court. This is not the issue in the present matter at all. What we had noticed and what was agreed by th....