Dama Seshadri Naidu, J.

Facts:

The appellant, a private limited company engaged in the production of steel, faced financial crises and has its manufacturing unit closed. In the process, the company ran into debts to the banks and other agencies; it has huge arrears of unpaid sales tax, too.

2. As one creditor bank took possession of the appellant's immovable property, the respondent department attached the company's movables-the machinery. In 2010, the third respondent, as a follow up, notified under the Revenue Recovery Act the sale of movables and machinery. Then, the third respondent valued the attached properties at Rs. 85,16,000/-. But the sale could not take place because of the appellant's objections on the valuation of the property. As a matter of further developments, the very assessment by the department fell for consideration before this Court, which directed the department to reassess the tax due. In the parallel debt recovery proceedings, the creditor bank seems to have valued the appellant's movable property including machinery at Rs. 1,09,12,500/-.

3. In view of the earlier aborted sale, the third respondent on 24.05.2016 freshly notified through Ext.P4 the sal