Provisional attachment under Section 83 needs prior opinion; a bare revenue-protection order is mechanically unsustainable

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....Provisional attachment of a bank account under Section 83 requires the competent authority to form a prior opinion before invoking the power. The cited Supreme Court authority treats the provision as draconian and insists on strict compliance with the statutory preconditions to prevent arbitrary interference with business activity. An attachment order that merely states it is issued to protect revenue, without recording the mandated opinion, is mechanically made and legally unsustainable; the bank account must be de-frozen.....