Demand notice and bank attachment fail where no assessment orders exist for the relevant years.

Where no assessment orders had been passed for the relevant assessment years, a demand notice and bank attachment for recovery could not validly stand. The Court noted that verification confirmed the absence of assessment orders for all three years in question, so there was no enforceable basis for issuing a recovery demand or attaching the assessee's bank account. The impugned notice and attachment were therefore held unsustainable and were set aside in favour of the assessee.

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Issues: Whether the demand notice and bank attachment could stand when no assessment orders had been passed for the relevant assessment years.

Analysis: The challenge was founded on the absence of assessment orders for the relevant years. On verification, it was informed to the Court that no assessment orders had been passed for all the three assessment years in question. In the absence of such assessment orders, there could be no demand notice and no attachment of the petitioner's bank account for recovery.

Conclusion: The impugned notice and the bank attachment were unsustainable and were set aside in favour of the assessee.

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