THE HONOURABLE SRI JUSTICE SUJOY PAUL AND THE HONOURABLE DR. JUSTICE G.RADHA RANI WRIT PETITION No.29787 OF 2024 ORDER: (per Hon’ble Sri Justice Sujoy Paul)

Sri Swaroop M.V., learned counsel represents on behalf of M/s.Mytri Indukuru, learned counsel for the petitioner and Sri Murali Krishna, learned Senior Standing Counsel for Income Tax Department, appears for respondent Nos.2 and 3.

2. With the consent, finally heard.

3. This petition filed under Article 226 of the Constitution of India takes exception to the order dated 26.05.2022 and the consequential attachment order, dated 17.10.2024, whereby invoking Section 179 of the Income Tax Act, 1961 (for short ‘the Act’), the petitioner-widow of the former Director is saddled with the liability.

4. Learned counsel for the petitioner submits that only upon receiving the said attachment order, the petitioner came to know about the original order dated 26.05.2022. Before issuing the order, dated 26.05.2022, the petitioner was never put to notice. He placed reliance on a recent judgment of this Court in Sri Subba Rao Pavuluri v. Assistant Commissioner of Income Tax, [W.P.No.8369 of 2023, dated 01.10.2024] and urged that in the manner section