Mr. Rajneesh, a resident individual, during the course of assessment proceedings, was found guilty of making false entries in his books of accounts…

(a) Yes, the action of the Assessing Officer is valid, since the Assessing Officer is empowered to provisionally attach any property of the assessee, by an order in writing, during the pendency of assessment or reassessment proceedings of any income which has escaped assessment or for imposition of penalty under section 271AAD (penalty leviable for false entry etc. in books of accounts) with the prior approval of the PCC or CC or PC or C or PDG or DG or PD or D of Income-tax, if he is of the opinion that it is necessary to do so for the purpose of protecting the interests of the revenue. Such provisional attachment can be made where the amount or aggregate of amounts of penalty likely to be imposed under section 271AAD exceeds 2crores. (B) The provisional attachment shall be valid till 30.11.2024 for a period of 6 months from the date of the order. The said period may be extended for a total period not exceeding two years or sixty days after the date of assessment or reassessment, whichever is later. (C) If Mr. Rajneesh furnishes a guarantee from a scheduled bank, for an amount not less than the fair market value of such provisionally attached property or for an amount which is sufficient to protect the interests of the Revenue, such provisional attachment can be revoked.