The petitioner, who was the wife of a director of SRT Company, challenged a notice issued by the Income Tax Department under section 226(3) of the Income-tax Act attaching her personal bank account for recovery of the company’s tax dues. The petitioner contended that she was neither a director, shareholder, nor employee of the company and that the attached bank account was held solely in her name. The Court noted that the Revenue did not dispute these facts and admitted that the petitioner had never been a director of the company against whom the tax liability had arisen. The Court held that the Income Tax Department could not attach the petitioner’s personal bank account merely because she was the spouse of a director. While recovery proceedings against the director might be possible under section 179 of the Act, such provisions had no application to the petitioner. Accordingly, the Court quashed the notice issued under section 226(3), set aside the attachment of the petitioner’s bank account, and directed its immediate release/de-freezing.