Allowing the petition the Court held that , power u/s 281B are drastic powers permitting the AO to attach any property of an assessee even before completion of assessment or reassessment . These powers are thus in the nature of attachment before judgement . They  have provisionally applicability and terms and limited life . Such powers must be exercised in appropriate cases for proper reasons . Such powers cannot be exercised merely by repeating the phraseology used in the section and recording the opinion of the officer passing such order that he was satisfied for the purpose of protecting the interest of revenue , it was necessary so to do. On facts when earlier assessment years Tribunal has suspended the recoveries arising out of demands made on similar issues .Order of provisional attachment is set aside .  (WP No. 2036 of 2019 dt 3-09 2019 ) (AY. 2016-17 )