Despite of notice of attachment the property was sold by the owner in favour of the petitioner. The Tax Recovery Officer issued on the assessee a notice dated 27-3-2019 and directed him to handover vacant and peaceful possession of the property to the department. The assessee filed a writ petition challenging the notice dated 27-3-2019. He stated that he was the bona fide purchaser of the property for value without notice. He had no idea about any such notice being issued by the department to Shri Aziz Ahmed Shaikh and he had also no idea that the property was already attached by the department. He placed reliance on provisions of section 281. The assessee on being asked by the Court pointed out that he has not so far responded in any manner to the notice dated 27-3-2019.  If the assessee is seeking to rely upon the proviso (i) to section 281, he needs to point out to the authority concerned that the purchase of the attached property was for adequate consideration and without notice of the pendency of any proceedings against the defaulter Shri Aziz Ahmed Shaikh and that too the transfer was before the service of notice under rule 2 of the Second Schedule to the Income-tax Act. The assessee shall appear before the Tax Recovery Officer at the earliest and adduce necessary evidence and also make good his case for discharging the notice dated 27-3-2019. The authority concerned shall hear the assessee and pass appropriate order in accordance with law. It is expected by the authority concerned not to take any coercive steps against the assessee till the completion of this exercise as directed by the Court.