Tax as first charge on property: provisional attachment can secure government revenue during specified GST proceedings. Section 82 makes tax, interest and penalty a first charge on the property of the liable person. Section 83 permits the Commissioner to issue a written order to provisionally attach any property, including bank accounts, during specified GST proceedings to protect Government revenue, provided the Commissioner records a reasoned opinion based on due diligence and prima facie evidence. Provisional attachments must be in prescribed form, communicated to revenue authorities and the person concerned, lapse after one year, and include procedures for perishable goods, objections, court-custodied property and charging a partner's interest.