The effect of Section 83 of the Act shall come to an end as soon as the proceedings pending in any of the aforesaid Sections i.e. 63 or 64 or 67 or 73 or 74 are over because pendency of the proceedings is the sine qua non and in case the Commissioner still feel or is of the opinion that it is necessary so to do in the interest of protecting the Government revenue, it still can pass an order in writing to attach any 12 of 13 ::: Downloaded on - 15-09-2020 11:36:50 ::: www.taxguru.in CWP No. 11961 of 2020 (O&M) Page 13 of 13 property or even the bank account of the taxable person if the proceedings are initiated in any of the aforesaid provisions and are pending but for the provisions in which the proceedings have earlier been initiated and are over.UFV INDIA GLOBAL EDUCATION VS. UNION OF INDIA AND OTHERS Punjab and Hariyana High Court dt 9.9.2020