D.S.Tewatia, J.

1. Income-tax arrears amounting to Rs. 5,55,189 fell due from Messrs. Asia Electric Company, Phagwara, respondent No. 4. In order to realize the same, its factory building and the land underneath thereof situated at Phagwara was auctioned by Shri Sukh Dev Singh, Tax Recovery Officer (Income-tax), Amritsar, on May 18, 1969, for a sum of Rs. 96,000 to Kishan Chand Aggarwal, the petitioner--his bid being the highest. On June 11, 1969, the Income-tax Officer, Jullundur, filed his objections under rule 61 of Schedule II of the Income-tax Act, 1961 (hereinafter referred to as "the Schedule"). Even before these objections of the income-tax department were decided, the Tax Recovery Officer issued the sale certificate to the petitioner on June 24, 1969. The objections of the income-tax department were rejected by him, vide his order dated October 16, 1969. That order was, however, reversed in appeal by the Commissioner, Jullundur Division. A second appeal therefrom at the instance of the petitioner was dismissed by the Financial Commissioner, Punjab, as being incompetent. This led to the filing of Writ Petition No. 3384 of 1972, at the instance of the present petitio