2018 (4) TMI 577

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....court challenging the notice issued under section 226(3) of the Income Tax Act, 1961 addressed to the petitioner's bankers, viz., Canara Bank, Cutchery Road, V.H. Road, Erode, stating that the the petitioner is due and payable a sum of Rs. 6,82,18,782/-. Earlier, a notice was issued to the petitioner dated 26.03.2018, wherein, a payment of Rs. 4,61,50,180/- was made. It appears that this amount had increased to Rs. 6,82,18,782/- on account of the tax payable by the petitioner in respect of other assessment years other than the assessment year, viz., 2014-15. 3.The case of the petitioner is that as against the order passed by the Commissioner of Income Tax (Appeals)-III, Coimbatore, dated 14.02.2018, the petitioner has 30 days time fr....

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....der section 154 of the Income Tax Act, 1961 on 22.03.2018, after giving effect to the order dated 07.03.2018. Therefore, it is submitted that there is no error in the impugned notice. 5. Heard Mr.R.L.Ramani, learned Senior Counsel, appearing for the petitioner and Mr.A.P.Srinivas, learned Standing Counsel appearing for the 1st respondent. 6. The issue raised for consideration in this writ petition is whether the 1st respondent was justified in issuing notice under section 226(3) of the Income Tax Act, 1961? 7. Admittedly, on the date when the notice was issued, the petitioner has not preferred an appeal to the Income Tax Appellate Tribunal (ITAT) against the order passed by the Commissioner of Income Tax (Appeals)-III, Coimbatore, ....