OF

PROVISIONAL

ATTACHMENT

DTD.11.8.2022 PASSED UNDER SECTION 281B OF THE INCOME

TAX ACT 1961 BY THE R-1 WITH THE APPROVAL OF THE R-3

WHILST PROVISIONALLY ATTACHING THE FIXED DEPOSIT

TOTALING TO INR 3,700 CRORES (INDIAN RUPEES THREE

THOUSAND SEVEN HUNDRED CRORES) VIZ INR 2,600 CRORES

WITH HSBC BANK (ACCOUNT NO.073-161671-001) AND INR 1,100

CRORES WITH CITI BANK (ACCOUNT NO.521656018) ALONG

WITH INTEREST THEREUPON, WHEREBY AN ATTACHING HAS

BEEN MADE FOR A PERIOD OF SIX MONTHS (NEARING

ANNEXURE-A

BEARING

NO.ITBA.COM/F/A/2022-

23/1044616877(1).

THIS W.P. IS BEING HEARD AND RESERVED ON

17.10.2022, COMING ON FOR PRONOUNCEMENT OF ORDERS

THIS DAY, THE COURT MADE THE FOLLOWING:-

- 3 -

ORDER

In this petition, petitioner seeks quashing of the

impugned order at Annexure-A dated 11.08.2022 passed

by the 1^st respondent – Deputy Commissioner of Income

Tax under Section 281E of the Income Tax Act, 1961 (for

short ‘the I.T.Act’) whereby, pursuant to the approval dated

11.08.2022 of the 3^rd respondent – Principal Commissioner

of Income Tax, the 1^st respondent provisionally attached

the subject fixed deposits of the petitioner in a sum INR

3,700 crores viz., i.e. INR 2,600 crores with HSBC Bank

an