Section 245 & 281B of the Income Tax Act, 1961 — Recovery — Powers under section 281B are drastic powers permitting the AO to attach any property of an assessee even before the completion of assessment or reassessment, such powers must therefore be exercised in appropriate cases for proper reasons and cannot be exercised merely by repeating the phraseology used in the section and recording the opinion of the officer passing such order that he was satisfied for the purpose of protecting the interest of revenue,  it was necessary so to do. further for the earlier assessment years, Tribunal has suspended the recoveries arising out of the demands made by the AO in similar issues ; impugned order is set aside — Vodafone India Ltd. vs. Deputy Commissioner of income tax [2019] 311 CTR 210 (Bombay)