JUDGMENT Devan Ramachandran, J.

The appellants allege that the judgment of the learned Single Judge of this Court, dated 29.10.2025, is in error because, it has been issued without noticing the fact that the building in question – against which the tax assessment has been made – has been taken over by the 4^th respondent – Canara Bank, in the exercise of their powers under the Securitization and Reconstruction of Financial Assets and Enforcement of Security Interest Act , 2002 (SARFAESI ACT).

2. Sri.G.Hariharan – learned counsel for the appellants, submitted that, since the property has already been taken over in possession and is now proposed to be sold by the 4^th respondent – Canara Bank, the assessment ought to be honoured by them.

3. We notice that the learned Single Judge has repelled the afore contention, holding that the factum of the property having been taken over in possession by the Bank under the SARFAESI Act would have no consequence on its ownership; and hence that the liability to pay the tax assessed continues with the appellants.

4. Sri.B.S.Syamanthak – learned Government Pleader, submitted that since the assessment has not been challenged by the appellants at any po