Company Mahadev Floorings (India) Pvt. Ltd. was amalgamated with assessee-company. AO had reopened assessment of company Mahadev Floorings (India) Pvt. Ltd. and passed assessment order on raising tax demand upon it.  Subsequently Tax Recovery Officer issued on assessee-company a notice to recover tax dues of company Mahadev Floorings (India) Pvt. Ltd.   and on failure of assessee to pay tax dues of company Mahadev Floorings (India) Pvt. Ltd.   had attached bank accounts of assessee. On writ the court held that Tax Recovery Officer could not seek recovery of taxes due of Mahadev Floorings (India) Pvt. Ltd. arising out of order of reassessment from assessee-company inasmuch as assessee neither had been served with notice of reopening of assessment, nor had any occasion to participate in such reassessment proceedings. Accordingly the notice of recovery was set aside and attachment of bank accounts were lifted. (AY. 2010-11)