Court affirms Income Tax Appeals Commissioner's order on demand for AY 2017-18; upholds bank account attachment.

The court upheld the order passed by the Commissioner of Income Tax (Appeals) regarding the demand arising from an assessment order for the Assessment Year 2017-18. The court noted the petitioner's failure to comply with tax obligations but allowed the statutory appeal process to proceed unhindered. Additionally, the court found no reason to interfere with the attachment of the petitioner's bank account due to non-compliance with previous directions. The petitioner was advised to seek an early hearing and disposal of the appeal through the appropriate channels.

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Issues:
1. Challenge to the order passed by the Commissioner of Income Tax (Appeals) in a petition filed by the petitioner seeking stay of demand arising from an order of assessment for the Assessment Year 2017-18.
2. Challenge to the attachment of the petitioner's bank account due to non-compliance with directions in a previous order.

Analysis:

Issue 1:
The petitioner, a primary agricultural co-operative society, challenged the order passed by the Commissioner of Income Tax (Appeals) regarding a demand arising from an assessment order for the Assessment Year 2017-18. The petitioner had previously challenged the assessment order itself, which was rejected, granting the petitioner the liberty to file a statutory appeal. The issue in question related to substantial credits in the petitioner's bank accounts of demonetized notes, which were brought to tax as unexplained money under the Income Tax Act, 1961. The court noted that the petitioner had neither filed a return of income nor replied to notices prior to the assessment. However, since a statutory appeal against the assessment was pending, the court stated that the facts were noted for completion of the narration, and the appeal filed by the petitioner would be disposed of in accordance with the law without hindrance from any observations made in the current judgment.

Issue 2:
Due to the petitioner's non-compliance with directions in a previous order, the bank account of the petitioner was attached, leading to the filing of a petition challenging the attachment. The court found no reason to interfere with the attachment of the bank account based on the previous judgment dismissing the challenge to the order passed by the Commissioner of Income Tax (Appeals). The petitioner was advised to approach the Commissioner of Income Tax (Appeals) for an early hearing and disposal of the appeal. Consequently, the petition challenging the bank account attachment was also dismissed, and the petitioner was granted liberty to seek early hearing and disposal of the appeal.

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