High Court Stresses Fair Play in ACIT Attachment Orders u/s 226(3), Balancing Revenue Protection and Taxpayer Rights.

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....Attachment order passed by ACIT u/s 226(3) – AO is a prospector of the Revenue and he is no doubt expected to protect the interests of the Revenue zealously, but such zeal has to be tempered with the rules of fair play and an anxiety to ensure that an opportunity is not lost to the assessee - HC....