Sec. 220 & 132(9B) of Income-tax Act, 1961— Search & seizure - A search action under s. 132 of the Act, 1961 was undertaken. Later, the search action under s. 132 of the Act was carried out. The respondent passed an order under s. 132(9B) of the Act, whereby, the FDRs of two Banks came to be provisionally attached and order of such provisional attachment was served upon the writ applicant. The case of the Department is that the writ applicant is liable to pay a particular amount towards tax in India. With a view to secure such amount liable to be paid by way of tax, the Department had to pass the impugned order of provisional attachment of the FDRs of the two banks referred to above. Department submitted that if the writ applicant is permitted to operate bank accounts, it has no objection. However, the provisional attachment over the FDRs shall continue and it shall be open for the Department to initiate fresh action also in future in accordance with law. Appeal disposed of accordingly. - BEST OASIS LTD. V/s DEPUTY DIT - [2020] 315 CTR 467 (GUJ)