( 1 ) IN this writ application the petitioners who are trustees of a Public Charitable Trust (in short petitioner Trust) have challenged an order of attachment against shares owned by the petitioner Trust issued by the Tax Recovery Officer-II (Income Tax) Jaipur (in short TRO)under Rule 26 (1) (it) of the Second Schedule to the income Tax Act, 1961 (in short Act) for an alleged demand against a private trust known as Raja Baldeodas Birla Santatikosh Trust (hereinafter referred to as private Trust ). The order of attachment is in respect of shares of Jiyajeerao Cotton Mills Ltd, owned by the petitioner Trust and registered in the name of its Trustees and lying in its possession at its office at Calcutta. The said shares were received by the petitioner Trust from another Public Charitable Trust namely Birla Jan Kalyan Trust which had in its turn received such shares from Private Trust as donation. The other two Trusts also filed writ application on similar ground challenging the orders of the ITRO attaching such shares owned and held by them. The writ petitions challenging the orders of attachment were moved by the said two trusts and the petitioner trust on the same d