(1.) The petitioner has challenged the impugned attachment notice dated 22.03.2007 issued under Section 226(3) of the Income Tax Act, 1961.
(2.) The case of the petitioner is that the property in question which has been attached by the impugned notice dated 22.03.2007 was transferred in his favour under a Family Settlement Deed dated 11.10.2002 and a Registered Settlement Deed dated 11.06.2007.
(3.) It is submitted that the petitioner is not only in possession of the property but is also receiving rents from the tenants and therefore the question of attaching the property under the provisions of Section 226(3) of the Income Tax Act, 1961 does not arise.