, J.

1. The petitioner has challenged the legality of the notices issued under Section 281B of the income-tax Act (hereinafter referred to as "the Act"), by the Income-tax Officer, respondent No. 2, on March 14, 1984, vide which various bank deposits (F.D.Rs.) of the assesses lying in six different banks at Patiala and Chandigarh have been attached. Section 281B of the Act reads as under:

"281B. (I) Where, during the pendency of any proceeding for the assessment of any income or for the assessment or reassessment of any income which has escaped assessment, the Income-tax Officer is of opinion that for the purpose of protecting the. interests of the Revenue it is necessary so to do, he may, with the previous approval of the Commissioner, by order in writing, attach provisionally any property belonging to the assessee in the manner provided in the Second Schedule. (2) Every such provisional attachment shall cease to have effect after the expiry of a period of six months from the date of the order made under Sub-section (1): Provided that the Commissioner may, for reasons to be recorded in writing, extend the aforesaid period by such further period or periods as he thinks fit,