Court Allows Petitioner Partial Payments & Stays Bank Account Attachments

The court granted the petitioner's request to make partial payments within a specified period for each assessment year and provided a limited stay on the bank account attachments. The court emphasized compliance with the payment schedule and outlined consequences for non-compliance, allowing the petitioner to seek further relief through appropriate channels.

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Issues:
1. Writ of mandamus sought to lift bank account attachments.
2. Assessment orders passed against the petitioner for multiple years.
3. Bank accounts of the petitioner attached, affecting business activities.
4. Stay application filed for one assessment year, pending appeals for others.
5. Request for lifting attachments and making partial payments.
6. Arguments presented by both parties regarding the attachments.
7. Court's analysis of the situation and decision on the matter.

Analysis:
1. The petitioner sought a writ of mandamus to lift attachments on bank accounts by the respondent. The attachments were made through notices under section 226(3) for various assessment years. The petitioner claimed that the attachments severely impacted their business activities.

2. Assessment orders had been passed against the petitioner for multiple years, including 2012-13, 2015-16, 2016-17, and 2017-18. Appeals were filed for some years, but the orders were confirmed. The petitioner had also filed a stay application for the demand related to the 2012-13 assessment year, which was rejected by the ITAT.

3. The petitioner's bank accounts were attached, causing significant disruption to their business operations. The petitioner argued that they were willing to make partial payments towards the demands to seek relief from the attachments.

4. The petitioner had filed a stay application for the 2012-13 assessment year, which was dismissed by the ITAT. For the other assessment years, no such applications were filed either before the CIT (Appeals) or the ITAT. The petitioner requested the court to consider their willingness to make payments as a condition for lifting the attachments.

5. Both parties presented their arguments regarding the attachments and the petitioner's proposal to make partial payments. The respondent contended that substantial payments were necessary before considering lifting the bank account attachments.

6. The court considered the submissions from both sides and reviewed the case details. It noted that the petitioner had not filed stay applications for most assessment years and had only made an unsuccessful attempt for one year. The court then issued specific orders regarding partial payments and stay arrangements for different assessment years.

7. The court directed the petitioner to make partial payments within a specified period for each assessment year. It granted a stay for a limited period, allowing the petitioner to approach the relevant forums for further relief. The court also outlined the consequences of non-compliance with the payment schedule and emphasized the importance of following the court's directives to avoid further actions by the revenue authorities.

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