To protect interest of land revenue, Pallav's Gurgaon flat was attached under search and seizure conducted by authorized officer under Income Tax Act, 1961. It was attached with the order in writing from Director General

According to Section 132 (9B) of the Income Tax Act, 1961 where, during the course of the search or seizure or within a period of 60 days from the date of which the last of the authorizations for search was execute, the authorized office, for reasons to be recorded in writing, is satisfied that for the purpose of protecting the interest of revenue, it is necessary so to do, he may with the previous approval of the Principal Director General or Director General or the Principal Director or Director, by order in writing, attach provisionally any property belonging to the assesses, and for the said purposes. According to Section 132 (9C), every provisional attachment made under sub-section 9B shall cease to have effect after the expiry of six months from the date of order referred to in sub-section 9B. While applying the above provisions to given circumstances, it can be said that Pallav contention to Income Tax Authority is correct to lift the attachment as every provisional attachment shall cease to have effect after the expiry of six months from the date of order.