Finance/Compliance Consultant
77990 Points
Posted on 06 November 2026
Steps to get relief from the DRC-22 attachment:
• DRC-22 is provisional attachment under Sec 83 (to protect revenue during pending proceedings). Grounds are limited: it can be used only when proceedings under the specified sections (Sec 62, 63, 64, 67, 73, 74, 74A etc.) are pending. Ask which proceeding is pending.
• File objections within 7 days of attachment under Rule 159(5), with:
– proof that returns are filed
– that the dues are only for June 2022 (Rs 6 lakh)
– a payment plan.
You must be given a hearing.
• Release: pay the dues (or a part) and request release. The Commissioner releases the attachment in DRC-23 once the liability is paid or the property is no longer needed (Rule 159(6)).
• Attachment lapses automatically after one year from the order (Sec 83(2)).
• For a self-assessed liability that is merely unpaid, the proper route is recovery under Sec 79 (DRC-13 to the bank), with interest under Sec 50. You can also seek instalments under Sec 80 (up to 24 months, with Commissioner's approval).
• Courts have held provisional attachment is a "draconian" power (SC in Radha Krishan Industries, 2021). Cite it if procedure was not followed.