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Issues:
1. Validity of auctioning attached immovable properties. 2. Compliance with notice requirements before sale proclamation. 3. Compliance with limitation period for conducting the sale. Analysis: 1. The petitioners, as legal representatives of the assessee, challenged the auctioning of attached immovable properties as illegal, void, and arbitrary. They contended that the action was violative of rule 68B of the Income-tax Act, 1961. The respondent authorities opposed the claim, arguing that the objections filed by the petitioners were considered and rejected before the sale. The court found no merit in the petitioners' claim, stating that the sale proclamation was not in violation of natural justice principles. 2. The petitioners raised concerns about the lack of notice before the sale proclamation was issued. However, the court noted that the objections filed by the petitioners were duly considered and rejected by the third respondent. Therefore, the court concluded that there was no violation of principles of natural justice or fair play in the auction process. 3. The court examined the provisions of rule 68B of the Income-tax Act, particularly sub-rules (1) and (3), to determine compliance with the limitation period for conducting the sale. Sub-rule (3) specified that the relevant financial year for limitation computation was 1992-93, which ended on March 31, 1993. The sale, conducted on July 18, 1995, was within the three-year period from the end of the specified financial year. Consequently, the court held that the sale was not conducted beyond the prescribed limitation period. In conclusion, the court dismissed the writ petition, noting that the sale was conducted within the legal limitation period. The petitioners were not awarded costs but were allowed to pursue legal action as per the provisions of the Second Schedule to the Income-tax Act.
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