Hon'ble Prakash Krishna, J.—The petitioner, at the material time, was posted as senior manager of Kamla Nagar Branch of Canara Bank at Agra when he was served with a notice dated 5th of September, 2005 issued under Section 226 (3) of the Income Tax Act, 1961 (hereinafter referred to as the Act) by Tax Recovery Officer (Central), Kanpur for attaching the accounts of three persons namely (1) Mukesh Kumar Agrawal, proprietor of M/s. Singhal Casting Company Limited, (2) Sardar Paramjeet Singh and (3) M/s. Shivangi Steel Private Limited. It was stated that a sum of Rs. 41,43,342/- with interest is due from Mukesh Kumar Agrawal, the assessee, on account of income tax dues. It was directed to pay the said sum forthwith. Promptly, the petitioner submitted a reply on 8th of September, 2005 stating that M/s. Singhal Casting Company and M/s. Shivangi Steel Private Limited are enjoying open cash credit limits with the bank and are indebted to the bank. Sardar Paramjeet Singh is not having any account with the bank. The above attachment notice referred to above hereinafter is called as first notice.

2. Subsequent thereto, the Branch Manager, Canara Bank was served with another notice (h