Pursuant to search action in order to protect interest of revenue, assessee’s bank accounts and two immovable properties had been put under provisional attachment. On writ the Assessee submitted that he being 65 years of age, such action of Department which had virtually prevented him from accessing his own funds in bank accounts would cause great difficulty in meeting his day-to-day expenses, to meet with special requirements for medical attention for himself and his aged mother.  Further, attachment on movable properties being enough to cover all possible tax, interest and penalty which may arise even if all defences of assessee were negatived, attachment of back accounts be lifted.  Court held that in view of fact that assessee’s tax, interest and possible penalty liabilities were unlikely to exceed valuation of aforesaid two immovable properties, provisional attachment of his bank accounts was to be lifted without disturbing attachment of immovable properties till litigation with respect to alleged undisclosed foreign income was over. The petitioner is prevented from selling, transferring, creating any charge or encumbrances on the said two immovable properties till the present litigation is over or without leave of the Court