JUDGMENT

Dhiraj Singh Thakur, J. - The petitioner challenges the order dated 22nd December 2017 passed by the Income Tax Offcer under section 179 of the Income Tax Act, 1961 ('the Act') treating the petitioner liable for taxes allegedly due from the company M/s. Kaizen Automation Pvt. Ltd. (KAPL) for the assessment years 2008-09 and 2009-10. Order dated 18th March 2019 passed by the Principal Commissioner of Income-tax, Mumbai dismissing the revision petition under section 264 of the Act is also challenged in the present petition.

2. Briefy stated the material facts are as under :

2.1 A show cause notice dated 12th January 2017 was served upon the petitioner in terms of section 179 of the Act requiring the petitioner to show cause as to why recovery proceedings be not initiated against her in her capacity as a director of KAPL inasmuch as the assessee company was not traceable on the available addresses and further that the tax dues could not be recovered despite attachment of the bank accounts as the funds available were insuffcient. An amount of Rs.1404.42 lacs was thus sought to be recovered from the petitioner.

2.2 With a view to prove that the non-recovery of the taxes due could n