Background.
Under the scheme of the CGST Act, every taxable person shall be liable to pay tax on supplies of goods or services or both as per provisions of law. Accordingly, he should self-assess his tax liability for relevant tax period and furnish return with payment of due tax. This self-assessment is subject to scrutiny and examination by the departmental authorities by initiating proceeding under various sections. And, where it is noticed that tax has not paid or short paid or erroneously refunded or where input tax credit has been wrongly availed or utilised or tax collected but not paid to the Government, statutory orders are passed under relevant section to demand and recover such tax liability. However, such orders are subject to appeal and no recovery action can be initiated under section78 of the Act within three months from the date of service of such order. In some cases, taxable person during the pendency of proceeding, before amount became due for recovery, dispose of moveable and immoveable properties with intention of defrauding of Government revenue. Section 83 has been provided in the Act for provisional attachment of property in certain cases for the purpose of protecting the interest of revenue during the pendency of any proceeding under Chapter XII, Chapter XIV or Chapter XV, of the Act.
Relevant provisions
Section 83 of the CGST Act
Rule 159 of the CGST Rule
CBEC-20/16/05 2021 -GST/359 Dt 23.2.2021-(Guidelines for provisional attachment of property under section 83 of Act)
Section 83. Provisional attachment to protect revenue in certain cases.-
(1) Where, after the initiation of any proceeding under Chapter XII, Chapter XIV or Chapter XV, the Commissioner is of the opinion that for the purpose of protecting the interest of the Government revenue it is necessary so to do, he may, by order in writing, attach provisionally, any property, including bank account, belonging to the taxable person or any person specified in subsection (1A) of section 122, in such manner as may be prescribed
(2) Every such provisional attachment shall cease to have effect after the expiry of a period of one year from the date of the order made under sub-section (1).
Scope of section 83 of the CGST Act.
This section provides for provisional attachment of property for the purpose of protecting the interest of revenue during the pendency of any proceeding Chapter XII, Chapter XIV or Chapter XV, of the Act the Act.
Where, the Commissioner is of the opinion that for the purpose of protecting the interest of the Government revenue it is necessary so to do, he may, attach provisionally, any property, including bank account, belonging to the taxable person or any person specified in subsection (1A) of section 122, in such manner as may be prescribed.
Each such provisional attachment shall cease to have effect after the expiry of a period of | one year from the date of the order of attachment.
In the case of M/s Valerius Industries v Union of India 2019-TIOL-2094-HC-AHM-GST, the Gujarat High Court has laid down the principles for the construction of Section 83 of the Act and scope thereof, in the para 52.
Para 52 (1) The order of provisional attachment before the assessment order is made, may be justified if the assessing authority or any other authority empowered in law is of the opinion that it is necessary to protect the interest of revenue. However, the subjective satisfaction should be based on some credible materials or information.
(2) The power conferred upon the authority under Section 83 of the Act for provisional attachment could be termed as a very drastic and far-reaching power. Such power should be used sparingly and only on substantive weighty grounds and reasons.
(3) The power of provisional attachment under Section 83 of the Act should be exercised by the authority only if there is a reasonable apprehension that the assessee may default the ultimate collection of the demand that is likely to be raised on completion of the assessment. It should, therefore, be exercised with extreme care and caution.
(4) The power under Section 83 of the Act for provisional attachment should be exercised only if there is sufficient material on record to justify the satisfaction that the assessee is about to dispose of wholly or any part of his/her property with a view to thwarting the ultimate collection of demand and in order to achieve the said objective, the attachment should be of the properties and to that extent, it is required to achieve this objective.
(5) The power under Section 83 of the Act should neither be used as a tool to harass the assessee nor should it be used in a manner which may have an irreversible detrimental effect on the business of the assessee.
(6) The attachment of bank account and trading assets should be resorted to only as a last resort or measure. The provisional attachment under Section 83 of the Act should not be equated with the attachment in the course of the recovery proceedings.
(7) The authority before exercising power under Section 83 of the Act for provisional attachment should take into consideration two things:(i) whether it is a revenue neutral situation.(ii) the statement of “output liability or input credit”. Having regard to the amount paid by reversing the input tax credit if the interest of the revenue is sufficiently secured, then the authority may not be justified in invoking its power under Section 83 of the Act for the purpose of provisional attachment.
The Supreme court (2021-TIOL-179-SC-GST ) in the case of M/s Radha Krishan Industries, laid down the principles for the construction of Section 83 of the Act and scope thereof, in the para
(i) The power to order a provisional attachment is entrusted during the pendency of proceedings under any one of six specified provisions: Sections 62, 63, 64, 67, 73 or 74. In other words, it is when a proceeding under any of these provisions is pending that a provisional attachment can be ordered;
(ii) The power to order a provisional attachment has been vested by the legislature in the Commissioner;
(iii) Before exercising the power, the Commissioner must be “of the opinion that for the purpose of protecting the interest of the government revenue, it is necessary so to do”;
(iv) The order for attachment must be in writing;
(v) The provisional attachment which is contemplated is of any property including a bank account belonging to the taxable person; and
(vi) The manner in which a provisional attachment is levied must be specified in the rules made pursuant to the provisions of the statute.
Under sub-Section (2) of Section 83, a provisional attachment ceases to have effect upon the expiry of a period of one year of the order being passed under sub-Section (1).
Competent authority
As per section 83 of the Act, the Commissioner or delegated authority has power to attach property during the pendency of specified proceedings under Act.
Conditions and grounds for attachment of property.
First- Proceeding under chapter Chapter XII, Chapter XIV or Chapter XV, of the Act should be pending.
This section provides for provisional attachment of property for the purpose of protecting the interest of revenue during the pendency of any proceeding Chapter XII, Chapter XIV or Chapter XV, of the Act the Act. Chapter XII contain provisions pertaining to section 59 self-assessment, section 60 provisional assessment, section 61 scrutiny of returns, section 62 assessment of non-filers of returns, section 63 assessment of unregistered persons, section 64 summary assessment. Chapter XIV contains provisions of section 67 to 72 relating to inspection, search, seizure and arrest. Chapter XV is regarding demand and recovery containing section from 73 to 84. It is pertinent to note that where proceeding under specified section is completed and order is issued no provisional attachment can be made under section 83. Pendency of the proceeding under aforesaid sections is the sine qua non for the provisional attachment of property under section 83.
Second- Commissioner must form an opinion that provisional attachment is necessary for the purpose of protecting the interest of the Government revenue.
Plain reading of section 83 indicate that that before exercising the power of provisional attachment, the Commissioner must be “of the opinion that for the purpose of protecting the interest of the government revenue, it is necessary so to do”. The Commissioner must have formed the opinion that provisional attachment of the property belonging to the taxable person is necessary for the purpose of protecting the interest of the Government revenue.
CBIC has issued guidelines for provisional attachment of property under section 83 of Act vide circular CBEC-20/16/05 2021 -GST/359 Dt 23.2.2021. As per para 3 of the said guidelines, “ for forming an opinion under section 83, it is important that Commissioner must exercise due diligence and duly consider as well as carefully examine all the facts of the case, including the nature of offence, amount of revenue involved, established nature of business and extent of investment in capital assets and reasons to believe that the taxable person, against whom the proceedings referred in section 83 are pending, may dispose of or remove the property, if not attached provisionally. And the basis, on which, Commissioner has formed such an opinion, should be duly recorded on file. It is reiterated that the power of provisional attachment must not be exercised in a routine/mechanical manner and careful examination of all the facts of the case is important to determine whether the case(s) is fit for exercising power under section 83. The collective evidence, based on the proceedings/ enquiry conducted in the case, must indicate that prima-facie a case has been made out against the taxpayer, before going ahead with any provisional attachment. The remedy of attachment being, by its very nature, extraordinary, has to be resorted to with utmost circumspection and with maximum care and caution.”
On this issue, the in the case of M/s Radha Krishan Industries, (2021-TIOL-179-SC-GST ) has observed that “ The exercise of the power for ordering a provisional attachment must be preceded by the formation of an opinion by the Commissioner that it is necessary so to do for the purpose of protecting the interest of the government revenue. Before ordering a provisional attachment, the Commissioner must form an opinion on the basis of tangible material that the assessee is likely to defeat the demand, if any, and that, therefore, it is necessary so to do for the purpose of protecting the interest of the government revenue. The expression “necessary so to do for protecting the government revenue” implicates that the interests of the government revenue cannot be protected without ordering a provisional attachment. The formation of an opinion by the Commissioner under Section 83(1) must be based on tangible material bearing on the necessity of ordering a provisional attachment for the purpose of protecting the interest of the government revenue.” Relevant important observation are reproduced hereunder.
Para 48 -Now in this backdrop, it becomes necessary to emphasize that before the Commissioner can levy a provisional attachment, there must be a formation of “the opinion” and that it is necessary “so to do” for the purpose of protecting the interest of the government revenue. The power to levy a provisional attachment is draconian in nature. By the exercise of the power, a property belonging to the taxable person may be attached, including a bank account. The attachment is provisional and the statute has contemplated an attachment during the pendency of the proceedings under the stipulated statutory provisions noticed earlier. An attachment which is contemplated in Section 83 is, in other words, at a stage which is anterior to the finalization of an assessment or the raising of a demand. Conscious as the legislature was of the draconian nature of the power and the serious consequences which emanate from the attachment of any property including a bank account of the taxable person, it conditioned the exercise of the power by employing specific statutory language which conditions the exercise of the power. The language of the statute indicates first, the necessity of the formation of opinion by the Commissioner; second, the formation of opinion before ordering a provisional attachment; third the existence of opinion that it is necessary so to do for the purpose of protecting the interest of the government revenue; fourth, the issuance of an order in writing for the attachment of any property of the taxable person; and fifth, the observance by the Commissioner of the provisions contained in the rules in regard to the manner of attachment. Each of these components of the statute are integral to a valid exercise of power. In other words, when the exercise of the power is challenged, the validity of its exercise will depend on a strict and punctilious observance of the statutory pre-conditions by the Commissioner. While conditioning the exercise of the power on the formation of an opinion by the Commissioner that “for the purpose of protecting the interest of the government revenue, it is necessary so to do”, it is evident that the statute has not left the formation of opinion to an unguided subjective discretion of the Commissioner. The formation of the opinion must bear a proximate and live nexus to the purpose of protecting the interest of the government revenue.
Para49- By utilizing the expression “it is necessary so to do” the legislature has evinced an intent that an attachment is authorized not merely because it is expedient to do so (or profitable or practicable for the revenue to do so) but because it is necessary to do so in order to protect interest of the government revenue. Necessity postulates that the interest of the revenue can be protected only by a provisional attachment without which the interest of the revenue would stand defeated. Necessity in other words postulates a more stringent requirement than a mere expediency. A provisional attachment under Section 83 is contemplated during the pendency of certain proceedings, meaning thereby that a final demand or liability is yet to be crystallized. An anticipatory attachment of this nature must strictly conform to the requirements, both substantive and procedural, embodied in the statute and the rules. The exercise of unguided discretion cannot be permissible because it will leave citizens and their legitimate business activities to the peril of arbitrary power. Each of these ingredients must be strictly applied before a provisional attachment on the property of an assesses can be levied. The Commissioner must be alive to the fact that such provisions are not intended to authorize Commissioners to make premptive strikes on the property of the assessee, merely because property is available for being attached. There must be a valid formation of the opinion that a provisional attachment is necessary for the purpose of protecting the interest of the government revenue.
Para50- These expressions in regard to both the purpose and necessity of provisional attachment implicate the doctrine of proportionality. Proportionality mandates the existence of a proximate or live link between the need for the attachment and the purpose which it is intended to secure. It also postulates the maintenance of a proportion between the nature and extent of the attachment and the purpose which is sought to be served by ordering it. Moreover, the words embodied in sub-Section (1) of Section 83, as interpreted above, would leave no manner of doubt that while ordering a provisional attachment the Commissioner must in the formation of the opinion act on the basis of tangible material on the basis of which the formation of opinion is based in regard to the existence of the statutory requirement. While dealing with a similar provision contained in Section 45 36 of the Gujarat Value Added Tax Act 2003 , one of us (Hon’ble Mr Justice MR Shah) speaking for a Division Bench of the Gujarat High Court in Vishwanath Realtor v State of Gujarat 37 observed:
“8.3. Section 45 of the VAT Act confers powers upon the Commissioner to pass the order of provisional attachment of any property belonging to the dealer during the pendency of any proceedings of assessment or reassessment of turnover escaping assessment. However, the order of provisional attachment can be passed by the Commissioner when the Commissioner is of the opinion that for the purpose of protecting the interest of the Government Revenue, it is necessary so to do. Therefore, before passing the order of provisional attachment, there must be an opinion formed by the Commissioner that for the purpose of protecting the interest of the Government Revenue during the pendency of any proceedings of assessment or reassessment, it is necessary to attach provisionally any property belonging to the dealer. However, such satisfaction must be on some tangible material on objective facts with the Commissioner. In a given case, on the basis of the past conduct of the dealer and on the basis of some reliable information that the dealer is likely to defeat the claim of the Revenue in case any order is passed against the dealer under the VAT Act and/or the dealer is likely to sale his properties and/or sale and/or dispose of the properties and in case after the conclusion of the assessment/reassessment proceedings, if there is any tax liability, the Revenue may not be in a position to recover the amount thereafter, in such a case only, however, on formation of subjective satisfaction/opinion, the Commissioner may exercise the powers under Section 45 of the VAT Act.”
Cases fit for provisional attachment of property .
CBIC has issued guidelines for provisional attachment of property under section 83 of Act vide circular CBEC-20/16/05 2021 -GST/359 Dt 23.2.2021. As per para 3 of the said guidelines cases fit for provisional attachment of property are as under.
As mentioned above, the remedy of attachment being, by its very nature, extraordinary, needs to be resorted to with utmost circumspection and with maximum care and caution. It normally should not be invoked in cases of technical nature and should be resorted to mainly in cases where there is an evasion of tax or where wrongful input tax credit is availed or utilizs d or wrongfully passed on. While the specific facts of the case need to be examined in detail before forming an opinion in the matter, the following are some of type of cases, where provisional attachment can be considered to be resorted to, subject to specific facts of the case:
Where taxable person has:
a. supplied any goods or services or both without issue of any invoice, in violation of the provisions of the Act or the rules made there under, with an intention to evade tax; or
b. issued any invoice or bill without supply of goods or services or both in violation of the provisions of the Act, or the rules made there under; or
c. availed input tax credit using the invoice or bill referred to in clause (b) or fraudulently availed input tax credit without any invoice or bill; or
d. collected any amount as tax but has failed to pay the same to the Government beyond a period of three months from the date on which such payment becomes due; or
e. fraudulently obtained refund; or
f. passed on input tax credit fraudulently to the recipients but has not paid the commensurate tax.
In the case of M/s Patran Steel Rolling Mill v Assistant Commissioner of State Tax Unit 2 2019 (20) GSTL 732 (Gujarat) (2018-TIOL-2937-HC-AHM-GST,) the Gujarat High Court cited two instances in which provisional attachment would be apposite, these being where the assessee is a ‘fly by night operator’ and if the assessee will not be able to pay its dues after assessment.
Persons whose properties are liable for attachment.
As per provisions of section 83, Where, the Commissioner is of the opinion that for the purpose of protecting the interest of the Government revenue it is necessary so to do, he may, attach provisionally, any property, including bank account, belonging to the taxable person or any person specified in subsection (1A) of section 122, in such manner as may be prescribed. Thus, property of taxable as well as non- taxable persons may be attached under said section. In view of section 2(107) “taxable person” means person who is registered or liable to be registered under section 22 or 24. Person covered under 122(1A), who retain the benefit of transactions covered under clauses (i), (ii), (vii), or (ix) of section 122(1) and at whose instance such transaction is conducted shall liable for said provisional attachment subject to satisfaction of prescribed conditions..
Types of property that can be attached.
Section 83 provides that the provisional attachment which is contemplated is of any property including a bank account belonging to the said persons. CBIC has issued guidelines for provisional attachment of property under section 83 of Act vide circular CBEC-20/16/05 2021 -GST/359 Dt 23.2.2021. As per para 3 of the said guidelines details of types of property can be attached are as under.
It should be ensured that the value of property attached provisionally is not excessive The | provisional attachment of property shall be to the extent it is required to protect the interest of revenue, that is to say, the value of attached property should be as near as possible to the estimated | amount of pending revenue against such person.
More than one property may be attached in case value of one property is not sufficient to cover the estimated amount of pending revenue against such person. Further, different properties of the taxpayer can be attached at different points of time subject to the conditions specified in section 83 of the Act.
It may be noted that the provisional attachment can be made only of the properties to the taxable person, against whom the proceedings mentioned under section 83 of the Act are pending.
Movable property should normally be attached only if the immovable property, available for attachment, is not sufficient to protect the interests of revenue.
As far as possible, it should also be ensured that such attachment does not hamper normal business activities of the taxable person. This would mean that raw materials and inputs — for production or finished goods should not normally be attached by the Department.
In cases where the movable property, including bank account, belonging to taxable person has been attached, such movable property may be released if taxable person offers, in lieu of movable property, any other immovable property which is sufficient to protect the interest of revenue. Such immovable property should be of value not less than the tax amount in dispute. It should also be free from any subsisting charge, liens, mortgages or encumbrances, property tax fully paid up to date and not involved in any legal dispute. The taxable person must produce the original title deeds and other necessary information relating to the property, for the satisfaction of the concerned officer.
Period of attachment.
As per sub-Section (2) of section 83 , every provisional attachment shall cease to have effect after the expiry of a period of one year from the date of the provisional attachment order. Besides, the provisional attachment order shall also cease to have effect if an order in FORM GST DRC-23 for release of such property is made by the Commissioner. After final order has been passed under the specified proceedings, no proceeding will be pending and as a result of which the provisional attachment must come to an end.
An order of attachment.
Section 83 makes explicitly clear that the Commissioner should pass order in writing for the purpose of provisional attachment of the property. Procedure for the said attachment has been prescribed in the rule 159.
Where the Commissioner decides to attach any property, including bank account in accordance with the provisions of section 83, he shall pass an order in FORM GST DRC-22 to that effect mentioning therein, the details of property which is attached.
The Commissioner shall send a copy of the order of attachment 14[in FORM GST DRC-22] to the concerned Revenue Authority or Transport Authority or any such Authority to place encumbrance on the said movable or immovable property, which shall be removed only on the written instructions from the Commissioner to that effect or on expiry of a period of one year from the date of issuance of order under sub-rule (1), whichever is earlier] and a copy of such order shall also be sent to the person whose property is being attached under section 83
A copy of the order of attachment should be sent to the concerned Revenue Authority or Transport Authority or Bank or the relevant Authority to place encumbrance on the said movable or immovable property. The property, thus attached, shall be removed only on the written instructions from the Commissioner. There is no provision in the section and rule regarding giving an opportunity of being heard before issue of said order.
A copy of such attachment order shall be provided to the said taxable person as early as possible so that objections, if any, to the said attachment can be made by the taxable person.
Objection to attachment and revocation of attachment order.
Under the provisions of Rule 159(5), the person whose property is attached is entitled to submit objections on the ground that the property was or is not liable to attachment; and shall file an objection in FORM GST DRC 22A. The Commissioner shall , after affording an opportunity of being heard to the person filing the objection, decide the application and release the said property by an order in FORM GST DRC-23
A copy of such attachment order shall be provided to the said taxable person as early as possible so that objections, if any, to the said attachment can be made by the taxable person within the time period prescribed under rule 159 of the CGST Rules. If such objection is filed by the taxable person, Commissioner should provide an opportunity of being heard to the person filing the objection. After considering the facts presented by the person in his written objection as well as the during property the is personal still required hearing, to be if continued any, the Commissioner to be attached should or not, form and pass a reasoned an order view in writing whether to this effect. In case, the Commissioner is satisfied that the property was or is no longer liable for attachment, he may release such property by issuing an order in FORM GST DRC- 23.
Even in cases where objection is not filed within the time prescribed under rule 159(5) of CGST Rules, the Commissioner may take the grounds mentioned in the ‘said objection/representation on record and pass a reasoned order. Where the Commissioner is satisfied that the property was or is no longer liable for attachment, he may release such property by issuing an order in FORM GST DRC- 23
Completion of Investigation and Adjudication on priority.
Every provisional attachment shall cease to have effect after the expiry of a period of one year from the date of the provisional attachment order. This suggest that pending proceeding must be completed within one year. It is clarified in the aforesaid circular that As the provisional attachment of property is resorted to protect the interests of the revenue and may also affect the working capital of the taxable person, it may be endeavored that in all such cases, the investigation and adjudication are completed at the earliest, well within the peri ad of attachment, so that the due liability of tax as well as interest, penalty etc. arising upon adjudication can be recovered from the said taxable person and the purpose of attachment is achieved.
Release of attached property.
As per Rule 159(5), any person whose property is attached may 21[file an objection in FORM GST DRC-22A] to the effect that the property attached was or is Not liable to attachment, and the Commissioner may, after affording an opportunity of being heard to the person filing the objection, release the said property by an order in FORM GST DRC-23.
Even in cases where objection is not filed within the time prescribed under rule 159(5) of CGST Rules, the Commissioner may take the grounds mentioned in the ‘said objection/representation on record and pass a reasoned order. Where the Commissioner is satisfied that the property was or is no longer liable for attachment, he may release such property by issuing an order in FORM GST DRC- 23.
It is further provided in Rule 159(6) that the Commissioner may, upon being satisfied that the property was, or is No longer liable for attachment, release such property by issuing an order in FORM GST DRC-23
Disposal of attached property.
In case the taxable person fails to pay the said amount, then the said property of perishable/hazardous nature may be disposed as provided in rule 159. It is clarified in afore said circular that “ If the provisionally attached property is of perishable/hazardous nature, then such property shall be released to the taxable person by issuing order in FORM GST DRC-23, after taxable person pays an amount equivalent to the market price of such property or the amount that is or may become payable by the taxable person, whichever is lower, and submits proof of payment. In case the taxable person fails to pay the said amount, then the said property of perishable/hazardous nature may be disposed of and the amount recovered from such disposal of property shall be adjustable against the tax, interest, penalty, fee or any other amount payable by the taxable petson. Further, the sale proceeds thus obtained must be deposited in the nearest Government Treasury or branch of any nationalised bank in fixed deposit and the receipt thereof must be retained for record, so that the same can be adjusted against the amount determined to be recoverable from the said taxable person.
Care and caution to be taken.
The power to order a provisional attachment of the property of the taxable person including a bank account is draconian in nature and the conditions which are prescribed by the statute for a valid exercise of the power must be strictly fulfilled. In this regard , CBIC has issued guidelines vide aforesaid circular that “ It is reiterated that the power of provisional attachment must not be exercised in a routine/mechanical manner and careful examination of all the facts of the case is important to determine whether the case(s) is fit for exercising power under section 83. The collective evidence, based on the proceedings/ enquiry conducted in the case, must indicate that prima-facie a case has been made out against the taxpayer, before going ahead with any provisional attachment. The remedy of attachment being, by its very nature, extraordinary, has to be resorted to with utmost circumspection and with maximum care and caution.”
In the case of M/s Arya Metacast Pvt. Ltd. 2022-TIOL-476-HC-AHM-GST had inter alia held that the powers of section 83 of provisional attachment needs to be taken recourse of sparingly; that it should not be used as a tool to harass the assessee nor should it be used in any manner that it may have irresistible detrimental effect on the business of the assessee. And Procedure that had been required to be followed as per the Circular [ CBEC-20/16/05-2021-GST/359 dated 23 February 2021.
Conclusion
The Supreme Court in the case of M/s Radha Krishan Industries, (2021-TIOL-179-SC-GST ) has laid down following principles which are required to be considered while making provisional attachment of property by exercising power vested under section 83.
The power to order a provisional attachment of the property of the taxable person including a bank account is draconian in nature and the conditions which are prescribed by the statute for a valid exercise of the power must be strictly fulfilled.
The exercise of the power for ordering a provisional attachment must be preceded by the formation of an opinion by the Commissioner that it is necessary so to do for the purpose of protecting the interest of the government revenue. Before ordering a provisional attachment the Commissioner must form an opinion on the basis of tangible material that the assessee is likely to defeat the demand, if any, and that therefore, it is necessary so to do for the purpose of protecting the interest of the government revenue.
The expression “necessary so to do for protecting the government revenue” implicates that the interests of the government revenue cannot be protected without ordering a provisional attachment.
The formation of an opinion by the Commissioner under Section 83(1) must be based on tangible material bearing on the necessity of ordering a provisional attachment for the purpose of protecting the interest of the government revenue.
Under the provisions of Rule 159(5), the person whose property is attached is entitled to dual procedural safeguards:(a) An entitlement to submit objections on the ground that the property was or is not liable to attachment; and(b) An opportunity of being heard;
The Commissioner is duty bound to give opportunity of being heard and deal with the objections to the attachment by passing a reasoned order which must be communicated to the taxable person whose property is attached.
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Author: Motiram Kanadje | Retired Joint Commissioner of State Tax | Email: momakanadje@gmail.com
Disclaimer: Nothing contained in this document is to be construed as legal opinion or view of author whatsoever and the content is to be used strictly for informational and educational purposes. While due care has been taken in preparing this article, certain mistakes and omissions may creep in. The author does not accept any liability for any loss or damage of any kind arising out of any inaccurate or incomplete information in this article nor for any action taken in reliance thereon.
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