Provisional Attachment under Section 281B – Requirement of Tangible Material and Consideration of Assessee’s Conduct

ARL Infratech Limited Vs DCIT (Rajasthan High Court) Core issue :Whether provisional attachment of property under Section 281B of the Income-tax Act, 1961 can be invoked without tangible material demonstrating likelihood of non-recovery of tax demand, particularly when the assessee has a history of being a regular taxpayer. Facts of the Case 1. The assessee company was engaged in manufacturing building materials such as cement sheets, cement pipes, AAC blocks, metal sheets and quartz slabs. 2. The assessee had paid income tax exceeding ₹45.43 crore for AY 2021-22 to AY 2026-27. 3. A search a...