Section 83(1)

"(1) Where, after the initiation of any proceeding under Chapter XII,
Chapter XIV or Chapter XV, the Commissioner is of the opinion that for the purpose
of protecting the interest of the Government revenue it is necessary so to do, he may,
by order in writing, attach provisionally, any property, including bank account,
belonging to the taxable person or any person specified in sub-section (IA) of section
122, in such manner as may be prescribed.".