The Department provisionally attached the bank account of the assessee under s. 281B during pendency of reassessment proceedings consequent to seizure of cash from a car. The assessee challenged the action contending that adequate security had already been furnished before the Magistrate Court pursuant to directions of the High Court, on the basis of which the seized amount was released, and that there was no tangible material to justify apprehension of evasion of tax. Allowing the writ petition, the Court held that sub-s. (3) of s. 281B contemplates furnishing of a bank guarantee equivalent to the fair market value of the property attached and reference to valuation under s. 142A, which indicates that the provision is intended to apply to immovable or similar properties requiring valuation and not to bank accounts, the value of which is self-evident. The impugned orders merely stated that reassessment proceedings were initiated and prior approval obtained, but did not disclose any tangible material forming the basis of the opinion that provisional attachment was necessary. In the absence of final adjudication of liability and particularly in view of security already furnished before the Magistrate Court, there was no justification for presuming that the assessee would evade payment of tax. Reference to r. 26 of Sch. II was also misplaced. Accordingly, the impugned provisional attachment orders were quashed.