Assessee, a regular taxpayer engaged in manufacturing, had its property provisionally attached under section 281B on apprehension of a demand of about ₹1.30 crore, though no demand had been created for relevant assessment years. Assessee contended that attachment was contrary to CBDT Office Memorandums prescribing a benchmark of 15-20 per cent deposit and violative of principles of natural justice. On writ, the Court held that  It was noted that the assessee had regularly paid taxes and only a small addition of ₹4.40 lakh was made for a prior year-Whether, since assessee was a regular taxpayer with only a small addition of ₹4.40 lakh for assessment year 2023-24 and no demand for assessment years 2022-23 and 2024-25, provisional attachment based merely on apprehension of demand was unjustified. Since section 281B is a draconian provision, the minimum requirement is to afford an opportunity to the assessee to make payment in terms of CBDT Office Memorandums, and no presumption can be drawn that the assessee would not make payment.  The attachment order was set aside with direction to the assessee to deposit 20 per cent of provisionally assessed demand within one week.   (AY. 2022-23 & 2024-25)