TaxTMI 
TaxTMI 
2005 (10) TMI 73
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....the petitioner seeking stay of recovery of demand for the assessment year 2002-03 and the petitioner has also challenged six notices all dated September 30, 2005, issued under section 226(3) of the Income-tax Act, 1961 ("the Act" for short), whereby various bank accounts of the petitioner have been attached. The assessment order under section 143(3) of the Act for the assessment year 2002-03 was passed by the Assessing Officer on March 31, 2005, inter alia, making addition of Rs. 210 crores by disallowing the marketing expenses and service charges claimed by the petitioner. In the light of the above addition, demand of tax and interest amounting to Rs. 77 crores has been raised against the assessee for the assessment year 2002-03. The appe....
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....ed senior counsel for the petitioner, the action of the Revenue in attaching the bank accounts of the petitioner even before serving the order of the Commissioner of Income-tax, dated September 19, 2005, is totally illegal and contrary to law. He submitted that the impugned order dated September 19, 2005, was posted on October 4, 2005, and the same was received by the petitioner on October 7, 2005. He submitted that by illegally attaching the bank accounts of the petitioner, the Revenue has already collected nearly Rs. 30 lakhs from the said bank accounts. He submitted that the orders passed by the Assistant Commissioner of Income-tax and the Commissioner of Income-tax, Pune, in rejecting the stay applications filed by the petitioner are al....
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....n the assessment year 2000-01 has been stayed by the Income-tax Appellate Tribunal subject to the petitioner paying Rs. 9 crores in instalments and furnishing adequate security to the satisfaction of the Assessing Officer. For the assessment year 2001-02, this court on a writ filed by the petitioner bearing Writ Petition No. 311 of 2005, by its order dated February 16, 2005, had stayed the demand of Rs. 73 crores subject to the petitioners depositing with the Income-tax Department Rs. 10 crores in instalments as more particularly stated therein. In this view of the matter, without going into the merits of the case, looking to the stay orders passed in the earlier years and in view of the facts that the appeals for earlier years are fixed fo....