Case Facts / Background:
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.

Cases Referred by Court:
None.