Provisional attachment of property requires prior notice and Commissioner initiation, non-compliance invites legal challenge. Attachment under Section 73C and the 2008 Rules requires issuance of a notice affording the assessee time to reply before attachment; non-compliance with Rule 3 and paragraph 2(iii) of the July 2008 Circular invalidates attachment actions. Attachment linked to ongoing show cause proceedings should be initiated by the Commissioner, and Chief Commissioners must issue standing orders to ensure careful exercise of attachment powers and compliance with procedural safeguards.