Honble VERMA, J.–The petitioner has filed the present writ petition as a Karta of Hindu Undivided Family i.e. H.U.F. against the Certificate issued by the Tax Recovery Officer under Section 222 of the Income Tax Act 1961. The petitioner submits that for an individual liability of the petitioner, the property of the H.U.F. neither can be attached nor auctioned for recovery of the arrears of income tax due from the petitioner Prakash Chand Lunia in individual capacity. Copy of the notice has been attached Annexure A to the writ petition wherein it is mentioned that Prakash Chand Lunia (defaulter) had failed to pay the sum of Rs. 3,00,61,927/-payable by him in respect of certificate No. 99/120 dated 27.7.1992, as forwarded by the Income Tax Officer Ward-2, Ajmer and the interest payable under Section 220(2) of the Income Tax Act 1961 and therefore, the Tax Recovery Officer had certified under Section 223(2) of the Act that the amount mentioned above is to be recovered from said Prakash Chand Lunia. Notice contained the specification of the property being House No. 10/265, situated at Niti Marg Ajmer, belonging to the H.U.F. property and one shop situated in Naya Bazar. It is mentioned

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