1) Section 25 of the recovery of debts Act to banks and FI 1993 prescribes various modes of recovery of the amounts indicated in the certificate. One of them is attachment and sale of immovable property of the judgment debtor. "S.25. The Recovery Officer shall, on receipt of the copy of the certificate under sub-section (7) of section 19, proceed to recover the amount of debt specified in the certificate by one or more of the following modes, namely:- (a) attachment and sale of the ***immoveable property of the defendant
2) The Second Schedule of the Income Tax Act read with the Income Tax Certificate Proceedings Rules, 1962, for short 'the 1962 Rules', prescribe the procedure for recovery of the amounts due pursuant to a certificate issued under Section 222 of the Income Tax Act. Part III of the Second Schedule prescribes the procedure for the attachment and sale of immovable property.
3) you need to make specifc averment that defaulter is the owner of property in dispute . enclose document in your possession that defaulter is the owner of said property .