(1)Where, during the pendency of any proceeding under section 28 or section 28-B, the proper officer is of the opinion that for the purpose of protecting the interests of revenue, it is necessary so to do, he may, with the previous approval of the Commissioner of Customs, by order in writing, attach provisionally any property belonging to the person on whom notice is served under sub-section (1) of section 28 or sub-section (2) of section 28-B, as the case may be, in accordance with the rules made in this behalf under section 142.