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

The last authorisation for a search on Arvind Mehta was executed on 1 June. The authorised officer, after recording reasons that it is necessary in the interest of revenue, provisionally attaches his property by order dated 20 July, with the required prior approval. Under section 247 of the Income-tax Act, 2025, the attachment is made within the permitted period and remains valid till:

The attachment is valid till 31 January of the following year. The order is within sixty days of the last authorisation, and validity runs six months from the end of the month of the order, which is 31 July, not from the order date.

A31 January of the following yearCorrect
B20 January of the following year
C30 September of the same year
D31 July of the next year

Explanation

The order on 20 July falls within sixty days of 1 June (1 June plus 60 days is 31 July). Under section 247(8)(b) validity is six months from the end of the month in which the order is made. The month end is 31 July, and six months from it is 31 January. Counting from 20 July gives 20 January, which is the mistake in that option.

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