Interim protection against tax recovery granted with conditions; TIN reopening allowed, but no relief for earlier years.

The Court permitted reopening of the applicant's TIN number and granted interim protection against coercive recovery of tax for the relevant assessment year, but only on strict conditions. The applicant was required to deposit part of the amount within two weeks and furnish a bank guarantee for the balance. The Court clarified that no interim protection was extended for earlier assessment years, and failure to comply would allow recovery of the full tax by coercive measures.

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Issues: Whether interim protection could be granted against recovery of tax for the assessment year 2011-12 and whether the TIN number could be reopened.

Analysis: The Court directed reopening of the applicant's TIN number and restrained coercive recovery of tax due for the relevant assessment period, subject to deposit of a part amount within two weeks and furnishing of a bank guarantee for the balance. The Court also clarified that no interim protection was granted for previous assessment years and that non-compliance would entitle the respondents to recover the full tax by coercive measures.

Conclusion: Interim relief was granted in favour of the applicant, subject to compliance with the stated conditions.

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