The fixed deposits of petitioner was attached invoking section 281B of the income-tax Act. On the ground that huge tax demands are likely to be raised. The assessee challenged the order by filing writ petition. Allowing the petition the Court held that mere apprehension on the part of the respondents that huge tax demands are likely to be raised on completion of assessment is not sufficient for the purpose of passing a provisional order of attachment. Exercise of power for order of provisional attachment must necessarily be preceded by formation of an opinion by the authorities that it is necessary to do so for the purpose of protecting the interest of Revenue. Before the order of provisional attachment, the CIT must form an opinion on the basis of the tangible material available for attachment that the assessee is not likely to fulfill the demand payment of tax and it is therefore necessary to do so for the purpose of protecting the interest of the Revenue-Radha Krishan Industries vs. State of Himachal Pradesh & Ors. (2021) SCC Online SC 334 followed. Order passed by the respondent was quashed.