V. Ramasubramanian, J.

1. The petitioner has come up with the above writ petition challenging an order of the Assistant Commissioner of Income Tax passed under Section 281 of the Income Tax Act, 1961 and an order of attachment of the property passed by the Tax Recovery Officer under Rule 48 of the Second Schedule to the Income Tax Act, 1961.

2. Heard Mr. S.Ravi, learned Senior Counsel appearing for the petitioner and Mr. J.V. Prasad, learned Senior Standing Counsel appearing for the Department.

3. The 3rd respondent-Company which is the assessee, became liable to pay income tax to the tune of Rs.1,92,27,635/-, for the period from 1995-96 to 2002-03. The 3rd respondent-Company was ordered to be wound up, by the Company Court in C.P.No.119 of 2002 by order dated 08-01-2003.

4. The 3rd respondent-Company admittedly owned two immoveable properties, one in Jubilee Hills, Hyderabad and another in Chakkarpur, Gurgaon District. By two registered sale deeds dated 20-6-2001 and 22-6-2001 bearing Document Nos.2038/2001 and 2057/2001, the 3rd respondent-Company sold the property at Jubi