Dismissing the petition the Court held that , a provisional attachment of properties can be made under S. 281B if there is reasonable apprehension that the assessee may default the ultimate collection of demand, i.e., likely to be raised on completion of the assessment. Court also held that the reasons provided for provisional attachment of properties had to be viewed in the background of the tax evasion allegedly conducted by the NDTV by floating paper companies to raise approximately Rs. 1,100 crores and later dissolving them. The annual reports and financial statements of the assessee showed that its net worth had constantly declined over the years. The order of provisional attachment of properties was justified. ( AY.2008 -09)