TMI Blog2013 (6) TMI 258X X X X Extracts X X X X X X X X Extracts X X X X ..... ed, the Revenue would be justified to attach the account to the extent of demand raised against an assessee and not the entire amount standing to the credit of the assessee. We find that the action of the Revenue in extending the period of attachment in respect of the all the bank accounts of the petitioner and in respect of over ₹ 33 lakhs in these circumstances is wholly unjustified and il ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ome-tax Act, 1961 (for short, the Act ). The amount of ₹ 12,13,023 as on May 27, 2011, was attached, vide annexure P.9 whereas the amount of ₹ 16,87,031 and ₹ 5,35,481 as on November 17, 2011, were attached, vide annexure P.10. Though the attach-ment was said to be operative for a period of two years up to December 12, 2003, in the aforesaid orders but by virtue of a subseque ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that the argument raised by the learned counsel for the petitioner is meritorious. The bank accounts of an assessee are provisionally attached to secure the interest of the Revenue pending assessment pro-ceedings to meet the eventuality of demand of tax to be raised against such assessee. Once the assessment has been completed, the Revenue would be justified to attach the account to the extent of ..... X X X X Extracts X X X X X X X X Extracts X X X X
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