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Authority's Power to Attach Bank Accounts u/s 83 Requires Justification Before Tax Liability Determination.
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....Attachment of Bank Accounts of petitioner - The power conferred upon an authority under Section 83 is substantial and with great power comes great responsibility. The authority concerned must justify the invocation of the coercive and intrusive recovery proceedings against the assessee, even prior to determination of liability and passing of an assessment order. The burden that lies upon the revenue is heavy and has to be seen to be discharged by them in a proper manner in each and every case where power under Section 83 is invoked. - HC....