The following core questions have been pro­pounded in this application under Article 226 of the Constitu­tion :

(i) Whether on withdrawal or cancellation of the recovery certificate by the Income Tax Officer u/s. 224 of the Income-tax Act, 1961, for short, 'the Act' the Tax Recovery Officer can proceed with the recovery proceedings under 'the Act'? if so, whether, in the case in hand, the Income-tax Officer with­drew or cancelled the Recovery Certificate issued by him ?

(ii) Whether the impugned recovery certificate dated 12.4.1954 was barred u/s. 46 of the Income-tax Act, 1922, for short 'the Old Act' read with Sec. 231 of 'the New Act" ?

(iii) Whether the recovery proceedings under 'the Act' are void illegal and without jurisdiction in the absence of a valid and enforceable recovery certificate and, therefore, the procee­dings should be quashed, the respondents be prohibited from and ordered not to give effect to the acts or actions in the course of the recovery proceedings and/or grant appropriate relief to the petitioner including an order restoring the pro­perty sold in the recovery proceedings ?

2. The application of the doctrine of consummation of sta­tutory remedy a