2019 (4) TMI 1672

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....ntial flats, in which, the Assessee was carrying on his business. 2. The provisional attachment order under Section 281B of the Income Tax Act, 1961 (hereinafter referred as "the Act") was issued on 29.10.2013, soon after the notices under Sections 147 and 148 of the Act for the Assessment Years 2011-12 and 2012-13 were issued. The said provisional attachment of the property was challenged by the Assessee on the ground that neither any notice was issued under Section 143(2) of the Act nor an assessment order was passed raising any demand. 3. Mr.N.Dilip Kumar, learned counsel for the appellant submitted that Section 281B of the Act provides for provisional attachment of the property of an Assessee against whom order has been issued in ....

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....t orders passed by the learned Commissioner of Income Tax dated 31.10.2015 for the three assessment years in question and he further submitted that huge demands have been made against the assessee and against these demands dated 31.10.2015, appeals have been filed by the assessee and they are also pending before the Commissioner of Income Tax (Appeals). 6. We have heard the learned counsel on both sides and also perused the records. 7. Section 281B of the Act is quoted below for ready reference: "Provisional attachment to protect revenue in certain cases: 281B:(1)Where, during the pendency of any proceeding for the assessment of any income or for the assessment or reassessment of any income which has escaped assessment, the [....