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CMA Final · Direct Tax Laws and International Taxation · Survey, Search and Seizure

A search under the Income-tax Act, 2025 was last authorised and executed on 20 January 2027. The authorised officer records reasons and, with the prior approval of the Director, provisionally attaches a property by order on 12 February 2027. Which is correct?

The attachment is within the sixty-day window and stays valid for six months from the end of the month of the order. The order was made in February 2027, so validity runs to 31 August 2027, not to 12 August.

  1. AThe attachment is within time and valid up to 31 August 2027Correct
  2. BThe attachment is within time and valid up to 12 August 2027
  3. CThe attachment is barred because it was made after the search ended
  4. DThe attachment is valid up to 31 July 2027

Explanation

Attachment may be made within sixty days of the last authorisation's execution; 12 February is within that. It is valid for six months from the end of the month of the order: end of February plus six months gives 31 August 2027. Counting six months from the order date (12 August) is the key mistake.

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