2019 (3) TMI 650

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....rivate Limited Company. Writ Petition Nos. 676 of 2019 and 673 of 2019 are filed by the directors of the company who are husband and wife respectively. 3. Search and seizure action was taken at the premises of the company leading to assessments under Section 153A of the Income Tax Act, 1961 ("the Act" for short). The directors were subjected to assessments under Section 153C of the Act for the assessment years 2010-11 to 2015-16. For the assessment year 2016-17, assessments under Section 143(3) of the Act were also framed. These assessment orders have given rise to combined income tax demand of Rs. 50 crores (approximately) in case of these three assesses. All the assessment orders have been challenged by the respondents assessees before t....

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....ntire tax dues. As part of coercive recoveries, the department has attached the bank accounts of all the assesses.   5. Learned counsel appearing for the petitioners submitted that :- i. The appeals of the individual assessees have been finally heard by the Appellate Commissioner and there is no further hearing to be done. In case of the company, the arguments on behalf of the assessee have already been made. He, however, clarified that there is a possibility of remand report being called for by the Appellate Commissioner. When the order of assessment was passed on 27.12.2017, no further recoveries may be permitted looking to the fact that all the appeals are at advance stage of hearing. He pointed out that even the Principal Commiss....