Allowing the petition the Court held that Held, that the before passing an order of provisional attachment, the authorities must form an opinion on the basis of tangible material available that the assessee is not likely to fulfil the demand payment of tax and it is therefore necessary to pass an order of provisional attachment for the purpose of protecting the interest of the Government revenue. In addition to these mandatory requirements, it is also incumbent upon the authorities to come to a conclusion based on tangible material that without the provisional attachment, it is not possible to protect the interest of revenue. On the facts the provisional attachment order was cryptic, unreasoned, non-speaking and laconic, and the same deserved to be quashed. Relied on  Radha Krishan Industries v. State Of Himachal Pradesh (2021)88 GSTR  228 (SC).