On writ against the provisional attachment the Court held that  the first charge holders of  the properties are the bankers and the  IT Department is  only the second charge holders of the assessee’s properties. Therefore, the first charge holders of the assessee’s properties, being the bankers, the assessee has to first satisfy the bankers, for availing loan facility and on the bankers are satisfied they would come forward to lend loan facility the assessees. The assessees have earned good reputation and credibility amongst the general public, based on which, the bankers have come forward to extend the loan facility and this is a continuous arrangements entered into between the bankers and the assessees, for the sake of running the business smoothly, and when the bank, having extended working capital loan facility to the assessees, and  they will monitor the same so as to protect their interest. The question of non-repayment would arise due to deficit in service of working capital loan extended to the  assessees. Therefore, the Department could have enabled the assessee to get their working capital loans extended by the bankers, and thereafter, monitor the assessee, whether such loan is being utilized by the assessee for the purpose, for which, such additional loan is extended, and by doing so, the interest of the Revenue, is not going to be affected any away, rather, it would promote much financial gain, and thereby, the interest of the Revenue would also be safeguarded. Therefore, the Department ought to have acted in such a way, in order to protect the interest of the Revenue. On the facts the Department has issued the attachment orders and the same got lapsed on 27th Aug., 2022, 22nd Feb., 2023 and 16th Aug., 2023 respectively. Finally, for the fourth time, the respondent Department has issued the provisional attachment orders dt. 16th Aug., 2023, and the reasons assigned is that to protect the interest of the Revenue. High Court passed the order   directing the Revenue to lift the attachment on bank account  to  enable the assessee to avail the working capital facilities etc. from the banks.   (SJ)