(x) If the person to whom a notice under this subsection is sent fails to make payment in pursuance thereof to the Income tax Officer, he shall be deemed to be an assessee in default in respect of the amount specified in the notice and further proceedings may be taken against him for the realisation of the amount as if it were an arrear of tax due from him, in the manner provided in sections 222 to 225 and the notice shall have the same effect as an attachment of a debt by the Tax Recovery Officer in exercise of his powers under sec tion 222." . . ." The argument of the learned counsel for the appellant is that on receipt of the I.T.O. 's notice under section 226(3) of the Income Tax Act, 1961, the L.I.C. was not left with the option to make the payment to assignee of the policies since the L.I.C. or its officer making the state ment on oath under section 226(3)(vi) would thereby have been exposed to personal liability as the defaulter of the income tax dues.