R. Subbiah, J.

1. This writ petition has been filed by the petitioner challenging the impugned order of attachment of the property of the petitioner, passed by the 2nd respondent under Section 281(b) of the Income-Tax Act, 1961.

2. The case of the petitioner, as set out in the affidavit, is as follows:-

2(a) The petitioner is an assessee on the file of the 2nd respondent under PAN-AVQPS2344J. During the year 2011, the petitioner purchased a piece of land admeasuring about 15698 sq.ft, comprised in S.F.No.643 situated at Andankoil East Village, Covaik Road, Reddi-Palayam, Karur, with the object of constructing 25 flats under the name and style of Apple Paradise. For the execution of the said project, loans were raised by the petitioner from the banking agencies like Can Fin Homes Ltd., Axis bank and prospective buyers, apart from obtaining periodical credits from supplier of building and other materials necessary for construction. Out of the 25 flats, 18 flats have been constructed and sold and remaining 7 flats are yet to be sold. As per project completion method, a recognized accounting method, the profit from the said project can accrue or arise or be ascertained only a