V.K. Singhal, J.—The petitioner is a partnership firm constituted by deed dated April 1, 1986. Theresa V. Murthy and P. J. Fernandez were the partners. Fernandez brought the property No. 44, Wellington Street, Civil Station, Bangalore, in the firm as contribution of his capital and Mrs. Murthy brought the property bearing No. 44/1, Wellington Street, Civil Station, Bangalore, as her capital. The firm was reconstituted on November 4, 1987, and Mr. Ghazenfer Basha was admitted as one of the partners. Again on March 2, 1988, Mr. Munavar Basha was admitted as partner and P.J. Fernandez retired from the firm. Mrs. Theresa V. Murthy also retired on March 23, 1991. P.J. Fernandez expired on March 7, 1990, and Mrs. Fernandez has also expired. Thereafter, a notice dated July 4, 1994, was served on the petitioner-firm that Mr. P.J. Fernandez was in arrear of Income Tax of Rs. 1,56,87,000. Property No. 44/1, Wellington Street, Civil Station, was attached on July 4, 1994. Objections were filed. Appeal under rule 86 of the Second Schedule to the Act was also filed which is stated to be pending. Directions were given in W. P. No. 29804 of 1994 to dispose of the said appeal. An order date