2010 (7) TMI 644

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.... is challenging the correctness and sustainability of Ext.P2 notice demanding a sum of Rs. 3,51,794 in respect of the assessment year 1999-2000 and Rs. 3,855 in respect of the assessment year 2005-06. Various contentions have been raised, particularly placing reliance on Ext.P3 order passed by the Commissioner of Income-tax (Appeals - V), whereby an observation has been made in paragraph 5 that, t....

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....ome-tax Act and is no with regard to the 'tax' element. The amount sought to be satisfied vide Ext P2 is in respect of the 'tax' payable by the petitioner for the concerned assessment years. The learned standing counsel also submits that, being aggrieved of the original assessment order dated 11-2-2004, in respect of the assessment year 1999-00, the petitioner had approached the Commissioner by fi....

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....d contend that no amount is liable to be paid by the petitioner and as such, no interference is warranted, submits the learned counsel. 4. This Court finds considerable force in the said submission. There is no case for the petitioner that, the petitioner has challenged fixation of tax liability, after the disposal of the statutory appeal on 21-12-2006, by resorting any procedure known to law a....