Attachment Notices Invalid for Lack of Basis; Statement in Inquiry Cannot Replace Formal Liability Determination u/s 70.

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....Recovery of dues - Validity of attachment notices - The impugned notice has no legs to stand. The respondent relies on the fact that there was a statement made by the petitioner in the course of an enquiry conducted by the Intelligence Officer under Section 70 of the Act. However, a statement recorded cannot substitute a determination of liability under an order of assessment or any other order passed under the applicable provisions under the Act. - HC....