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<h1>Provisional attachment of property to protect revenue permitted during specified tax proceedings, subject to due diligence and procedural safeguards.</h1> Provisional attachment under section 83 is available when the Commissioner, after due diligence and recording reasons, forms the opinion that attaching property belonging to the taxable person is necessary to protect Government revenue; attachment is effected by order in FORM GST DRC 22, the taxable person may object and seek hearing, and the Commissioner may release property by order in FORM GST DRC 23 where attachment is no longer warranted.