Statutory objection procedure governs tax recovery attachment disputes, requiring inquiry before further action against the property.

Rule 11 of Schedule II to the Income-tax Act, 1961 requires the Tax Recovery Officer to investigate claims and objections to attachment or proposed sale of property in execution of a recovery certificate. Where that statutory mechanism is available, it is neither necessary nor proper to decide disputed factual or legal issues at the stage of recovery proceedings. The Tax Recovery Officer was directed to examine the petitioner's objections in accordance with law, and any further action against the property was made conditional on the result of that inquiry.

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Issues: Whether objections raised against attachment and proposed sale of property in tax recovery proceedings had to be investigated by the Tax Recovery Officer under the statutory procedure.

Analysis: Rule 11 of Schedule II to the Income-tax Act, 1961 provides a specific mechanism for investigation of claims and objections to attachment or sale of property in execution of a certificate. Since that remedy was available, it was neither necessary nor proper to pronounce on the factual or legal disputes raised by the parties at that stage.

Conclusion: The Tax Recovery Officer was directed to investigate and adjudicate upon the petitioner's objections in accordance with law, and the further action against the property was made dependent on the result of that inquiry.

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