( 1 ) THREE orders of attachment issued under Section 281b of the Income-tax Act, 1961 (in short,the Act) are subject matter of challenge in this Writ Petition. The said orders were issued by the Deputy Commissioner of Income-tax, (Central) Circle-11 (in short Dyci), purportedly to protect the interest of revenue and after obtaining prior approval of the Commissioner of Income-tax (Central), (in short the Commissioner ). Total amount covered by the three orders aggregates to Rs. 23. 52 crores and were in respect of shares of and security deposit with M/s Sunair Hotels Ltd, and balance due from M/s Television (Eighteen) India Ltd.

( 2 ) FILTERING out unnecessary details, petitioner s ease is as follows: Petitioner company was incorporated in January, 1986 with the name of Vardhman Leasing and Services Ltd. The name was changed to VLS Finance Ltd on 8-9-1994. Petitioner, inter-alia, carries on the business of leasing, hire purchase, providing loan and finance to other corporate entities including portfolio management, corporate consultancy and capital market operations. It also carries on business of hire-purchase and leasing in respect of industrial and office equipme