Court orders petitioners to pay Rs.5 crores in installments, stays garnishee notice. Appeals to be expedited within 8 weeks.

The court directed the petitioners to pay Rs.5 crores in two equal monthly installments, staying the garnishee notice upon the payment of the first installment. The appellate authority was instructed to expedite the disposal of the appeals within 8 weeks, aiming to balance the interests of the tax authorities and the petitioners, allowing the business to continue operations and providing a fair opportunity for the petitioners to present their case.

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Issues:
1. Challenge to orders of assessment
2. Garnishee notice under Section 226(3) of the Income Tax Act
3. Bank accounts attachment
4. Stay of notice pending appeal
5. Timely disposal of appeals by the appellate authority

Analysis:
The writ petitions involved challenges to the orders of assessment issued to a partnership firm and a partner in the firm. The firm had filed an appeal against the assessment order, which was pending consideration. Meanwhile, a garnishee notice under Section 226(3) of the Income Tax Act was issued, demanding a substantial amount from the petitioners and attaching their bank accounts, leading to a halt in their business operations.

The main contention of the petitioners was the adverse impact of the notice on their business due to the attachment of bank accounts. The court acknowledged the significant amount demanded and the pending appeals. To address the situation, the court directed the petitioners to pay Rs.5 crores in two equal monthly installments, staying the notice upon the payment of the first installment. This decision aimed to balance the interests of the tax authorities and the petitioners, allowing the business to continue operations.

Furthermore, the court instructed the appellate authority to expedite the disposal of the appeals within 8 weeks of receiving a copy of the judgment. This directive ensured a timely resolution of the pending appeals, providing the petitioners with a fair opportunity to present their case before the appellate authority. Overall, the judgment sought to mitigate the immediate financial burden on the petitioners while ensuring a prompt resolution of the legal proceedings.

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