Court orders quick disposal of appeal, prohibits coercive steps by tax authority. Judgment emphasizes fairness and prompt action.

The court directed the Commissioner of Income Tax (Appeals) to dispose of the stay application and appeal within three weeks. It ordered a prohibition on coercive steps by the Income Tax Authority against the petitioner until a reasoned order is passed. The writ petition was disposed of without requiring an affidavit-in-opposition, with no costs imposed. The judgment aimed to address the inaction by authorities, payment under the Income Tax Act, and procedural fairness, providing a fair resolution for the petitioner.

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Issues:
1. Inaction by respondent authorities in considering stay application and appeal.
2. Payment made by petitioner under Section 220(6) of the Income Tax Act, 1961.
3. Bank account of petitioner seized and attached.
4. Direction to dispose of stay application and appeal within three weeks.
5. Prohibition on coercive steps by Income Tax Authority.
6. Disposal of the writ petition without calling for affidavit-in-opposition.
7. No order as to costs.

Analysis:
1. The judgment pertains to an application under Article 226 of the Constitution of India where the petitioner was aggrieved by the inaction of the respondent authorities in considering their stay application and appeal before the Commissioner of Income Tax (Appeals). The court noted that a sum of Rs. 14 lakh had already been paid by the petitioner under Section 220(6) of the Income Tax Act, 1961, with a further payment of Rs. 14 lakh pending. The petitioner expressed inability to make further payment due to their bank account being seized and attached.

2. Considering the above circumstances, the court deemed it just and fair to direct the Commissioner of Income Tax (Appeals) to dispose of the stay application and appeal within three weeks. It was further ordered that no coercive steps should be taken by the Income Tax Authority against the petitioner until a reasoned order is passed by the Appellate Authority.

3. The judgment also highlighted that the writ petition was disposed of without calling for an affidavit-in-opposition from the respondents. Therefore, the allegations made in the petition were deemed to have not been admitted by the respondents. Additionally, no costs were imposed in the matter.

4. Finally, the court directed that an urgent photostat certified copy of the order be provided to the parties upon compliance with all necessary formalities. This comprehensive judgment addressed the issues of inaction by authorities, payment under the Income Tax Act, prohibition on coercive steps, and the procedural aspects of the case, ensuring a fair and just resolution for the petitioner.

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