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Provisional attachment of Bank Accounts - On what basis, the Commissioner has decided to invoke Section 83 to go for a provisional attachment before which, whether the Commissioner has formed an opinion to do so, before forming such opinion, what are all the tangible material available before him or placed before him, so as to enable him to form such an opinion, all these aspects have not been even indicated in the order of provisional attachment. - The order of provisional attachment made by the first respondent dated 20.12.2021, shall not stand in the legal scrutiny. - HC