Bank Accounts Qualify as Attachable Property Under Section 281B Income Tax Act for Securing Revenue Interests

HC ruled bank accounts constitute "property" subject to provisional attachment under Section 281B of the Income Tax Act. The term "any property" in Section 281B(1) encompasses bank deposits, as money is explicitly recognized as attachable property under Section 60(1) CPC. The court rejected arguments that absence of specific mention of bank accounts (unlike GST Act) precludes attachment. However, attachment orders must be proportionate to probable tax demand including penalties. The security requirement should be sufficient to protect revenue interests without excessive property seizure. Mere existence of security in Magistrate's Court proceedings does not automatically satisfy Act's requirements. Blanket attachment orders exceeding probable demand are impermissible. .....

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