Case Facts:
The petitioner challenged a bank attachment notice issued for recovery of tax dues of a company in which he was a director. 
An assessment order had been passed against the company for the tax period 2018–19. 
The petitioner claimed resignation from the company and sought immunity under Section 89(1), submitting a representation to authorities. 
The company had separately challenged the assessment order, which was pending before the Court.

Court Decision:
The Court held that the issue of petitioner’s liability under Section 89 requires adjudication. 
It directed the authorities to treat the impugned attachment notice as a show cause notice and decide the matter after giving opportunity to the petitioner. 
The petitioner was directed to submit a detailed representation within 30 days, and the authority to pass orders within two months thereafter. 
The bank attachment was ordered to be lifted pending such adjudication, subject to conditions.