Stock Exchange, Ahmedabad vs Assistant Commissioner Of Income Tax

Whether the membership right/card of a deceased stock exchange member constitutes 'property belonging to the assessee' that can be provisionally attached under section 281B of the Income Tax Act, 1961, and whether garnishee proceedings under section 226(3) can be initiated against the stock exchange for amounts related to such membership --- Held: No. The membership is a personal permission, not a private asset, and upon death/default, the right of nomination vests absolutely in the stock exchange under its rules, making it not the property of the assessee or his legal heirs.