Attachment of property
 
  1). Where, during the pendency of any proceedings for the assessment of any turnover or for the reassessment of any turnover which has escaped assessment, the assessing authority is of the opinion that for the purpose of protecting the interest of 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.
  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(l):
    Provided that the Commissioner may, for reasons to be recorded in writing. extend~ the aforesaid period, or periods as he thinks fit, so, however, that the total period of extension shall not in any case exceed two years.