Section 15 in Income-Tax (Certificate Proceedings) Rules, 1962
15. Continuance of attachment subject to claim of encumbrancer - Where, in the course of investigation made under rule 11 of the principal rules, the Tax Recovery Officer is satisfied that the property is subject to a mortgage or charge (other than a mortgage or charge referred to in section 281 or rule 16 of the said rules) in favour of some person not in possession, and thinks fit to continue the attachment, he may do so, subject to such mortgage or charge.
