On writ, the court held that mere apprehension that huge tax demands are likely to be raised on completion of assessment is not sufficient for the purpose of passing a provisional attachment order and it must necessarily be preceded by the formation of an opinion that it was necessary to do so for the purpose of protecting the interest of Government revenue, that too on the basis of tangible material that the assessee was not likely to fulfil the demand and on the other hand, was likely to defeat the demand. The apprehension that huge tax demands are likely to be raised on completion of assessment is not sufficient to constitute the formation of opinion and existence of proximate and live link for the purpose and necessity of provisional attachment which implicate the doctrine of proportionality. Court also held that it is trite law that grant of approval should not be a mechanical act and should reflect the independent application of mind and this important safeguard of taking prior approval of the Commissioner under section 281B of the Income-tax Act, 1961 is not a mere empty formality and cannot be taken lightly. Court also directed that the respondents were to complete the draft assessment proceedings of the assessee for the assessment years 2019-20, 2020-21 and 2021-22 on or before March 31, 2023.(AY.2019-20 to 2021-22)