Supreme Court grants leave, directs tax appeal expedited, funds released, prohibits coercive actions

The Supreme Court granted leave in a case where the Writ Petitioner challenged the High Court's order dismissing their petition regarding tax demands. The Court directed the Commissioner of Income Tax (Appeals) to expedite pending appeals, withdraw attached funds, and allowed the appellant to keep a term deposit as security. The Income Tax Department was prohibited from further attachments or coercive actions during the appeal process. The Civil Appeals were disposed of with these directions to ensure a fair resolution and protect the appellant's interests.

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Issues Involved:
Challenge to High Court order dismissing writ petitions, rejection of stay applications by Commissioner of Income Tax (Appeals), attachment of appellant's bank accounts, direction to deposit 15% of total tax demand, appeal pending before CIT (Appeals), withdrawal of attached amount, security of term deposit, prohibition on further attachment or coercive steps.

Analysis:
The Supreme Court granted leave in the case where the Writ Petitioner (Assessee) challenged the High Court's order dismissing their petition. The Commissioner of Income Tax (Appeals) had rejected stay applications and directed the appellant to deposit 15% of the total tax demand for multiple assessment years. The appellant filed writ petitions before the Bombay High Court, which were also dismissed. The Attorney General highlighted that the appellant, a statutory corporation, had significant fixed term deposits in banks. The appellant's counsel mentioned that certain bank accounts were attached, while the fixed deposit amount belonged to the State Government.

The Supreme Court, without delving into the merits pending before the Commissioner of Income Tax (Appeals), issued specific directions. Firstly, the CIT (Appeals) was directed to decide the pending appeals within one month without unnecessary adjournments. Secondly, the Income Tax Department was instructed to withdraw the approximately Rs. 400 crores already attached. Thirdly, the appellant was directed to keep the term deposit of approximately Rs. 1000 crores as security until the appeal's disposal. Lastly, the Income Tax Department was prohibited from attaching any other accounts or taking coercive steps during the appeal's pendency.

In conclusion, the Civil Appeals were disposed of with the aforementioned directions, ensuring a fair and just resolution while safeguarding the appellant's interests during the ongoing appeal process before the CIT (Appeals).

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