Held: Although there is no specific challenge to the order passed by the Commissioner of State Tax delegating his power under Section 83 to the subordinate officers, yet, by virtue of such order, the impugned order of provisional attachment cannot be defended. The power conferred upon the authority under Section 83 of the Act for provisional attachment could be termed as a very drastic and far- reaching power. Such power should be used sparingly and only on substantive weighty grounds and reasons. The power of provisional attachment under Section 83 of the Act should be exercised by the authority only if there is a reasonable apprehension that the assessee may default the ultimate collection of the demand that is likely to be raised on completion of the assessment. The power under Section 83 of the Act should neither be used as a tool to harass the assessee nor should it be used in a manner which may have an irreversible detrimental effect on the business of the assessee  (SCA No. 13132 of 2019 dt  28th August, 2019  )