No Attachment Proceeding u/s 226 Possible if Debtor Disputes Debts !

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When there is tax demand against a tax payer, the provision under section 226 of the Income Tax Act empowers the assessing officer as well as Tax Recovery Officer to initiate attachment or garnishee proceeding against the assessee . So , if someone owes money to the tax payer against whom there is tax due, the A.O or TRO can attach the amount of debt to the extent of the demand of tax department. The issue , dealt in post is , whether the power of attachment can still be used when the tax payer claims a debt from say M/s X but X , on notice from the TRO disputes any amount due to the tax payer?

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