The writ applicant is aggrieved by the action of the revenue department putting the attached properties for sale by issue of proclamation for the purpose of recovery of the tax amount due and payable by the Company, in which, the writ applicant is one of the Directors. As noted above, an order under Section 179 of the Act also came to be passed by the Assessing Officer. The order passed under Section 179 of the Act attained finality. The same was not challenged by the writ applicant at any point of time.