Court rulings on tax assessments, recovery notices, and bank account attachments during COVID-19. Orders modified for relief.

The court addressed three writ petitions involving tax assessment, recovery notices, and bank account attachments during the COVID-19 pandemic. In two cases, attachment orders on bank accounts were lifted as the revenue authorities had already received the demanded amounts. In the third case, a separate fixed deposit account was ordered to hold the demanded amount pending appeal, allowing the petitioners to operate their bank account. The judgment highlighted the pandemic's impact on the petitioners' livelihood and emphasized expediting the appeal process. Parties were instructed to comply with the court's directives until normal court functions resumed.

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Issues:
Three writ petitions involving tax assessment, recovery notices, and bank account attachments amid COVID-19 pandemic.

Tax Assessment and Recovery Notices:
The petitioners, engaged in extending business opportunities to tribals, were assessed to tax by Income Tax authorities. Appeals and stay petitions were pending consideration. Income Tax authorities issued recovery notices and attached bank accounts of the petitioners. The petitioners argued that recovery notices should be stayed during appeal proceedings as per the usual practice upon depositing 20% of the demanded amount. Referring to a Supreme Court order during the COVID-19 pandemic, the petitioners requested permission to operate their bank accounts, highlighting the potential infringement of their livelihood guaranteed under Article 19(1)(g) of the Constitution of India.

Judgment Analysis - Writ Petitions:
In two writ petitions, the revenue authorities had already received the recovery amount from the banks before a Supreme Court order dated March 20, 2020. Therefore, the attachment orders on the bank accounts of the petitioners in these two cases were lifted. However, in the third writ petition, the demand notice was issued before the Supreme Court order. The court directed the bank to set aside the demanded amount in a separate interest-bearing fixed deposit account pending the appellate authority's decision. Once the amount was set aside, the petitioners were allowed to operate the bank account. This interim measure was deemed necessary due to the COVID-19 pandemic situation, with the appellate authority instructed to expedite the appeal process without prejudice to any party.

Conclusion:
The court's interim order addressed the differing circumstances of the three writ petitions concerning tax assessment, recovery notices, and bank account attachments. While the attachment orders were lifted in two cases due to the revenue authorities already receiving the demanded amounts, a separate arrangement was made for the third case to protect the petitioners' interests during the appeal process. The judgment emphasized the impact of the COVID-19 pandemic on the petitioners' ability to operate their bank accounts and highlighted the need for expeditious resolution of the pending appeals. The parties were instructed to follow the court's directives until normal court functions resumed.

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