Revenue provisionally attached the  fixed deposit of two banks. The assessee  filed the writ petition against the said attachment. allowing the petition the Court held that  mere apprehension that huge tax demands were likely to be raised on completion of assessment was not sufficient to constitute  formation of opinion for purpose of provisional attachment.  Order of provisional attachment is held to be illegal and arbitrary.  The order of attachment was  quashed and set aside. (AY. 2018-19)