The petitioner, the wife of an assessee in default, is before this Court aggrieved by Exhibits P9, P10 and P12 by which the Income-tax authorities proceeded against her property comprised in Survey Number 354/17/8, Re-survey number 681/9; which also adjoins the property in which the petitioner runs a hotel. The petitioner's husband is an assessee in default, of the tax assessed on him by reason of a block assessment made, pursuant to a search and inspection conducted in his residential premises.

2. Admittedly, a search and seizure under section 132 of the Income Tax Act, 1961 [for brevity "IT Act"] was made at the residential premises of the petitioner and her husband, on 24/09/1996; the materials seized thereat leading to a block assessment for the period 1986-87 to 1995-96. The tax liability was determined at Rs.4,00,36,404/-. The statutory appeal ultimately reduced the amount to Rs.1,03,89,878/-. The impugned action was to recover the said amount by attachment and sale of the property, owned by the petitioner as per Exhibit P1 and P2 deeds; conveyed to her for consideration. Whether the conveyance was a sham transaction, insofar as there being no adequate consideration