Powers of provisional attachment have been extended to proceeding under Chapter XII (Assessment), XIV (Inspection, Search, Seizure and Arrest) or XV (Demands and Recovery) for attachment of property including bank account belonging to the taxable person or person who has retained benefits of offences under Section 122(1A).
Through this amendment, the Commissioner has now been empowered to initiate provisional attachment proceedings even during the assessment, investigation etc., if he feels that provisional attachment is necessary to protect the revenue.
However, for the time being, the rule is that for initiating the provisional attachment proceedings, it is necessary to determine the liability and give reasonable time to discharge the obligation.