2025 (1) TMI 1351

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.... Sinha, Advocate, Mr. Manav Poddar, Advocate For the Respondents : Mr. Kumar Vaibhav,,Sr. Standing Counsel, ITD. 1. All these writ petitions have been prayed to be heard together since common issues are involved. 2. These writ petitions have been filed under Article 226 of the Constitution of India praying therein for following directions :- "W.P.(T) No.5141 of 2024 a) For quashing and setting aside the Notice of Demand dated 19.03.2018 (Annexure-2) issued by the Respondent No. 3, whereby the Petitioner has been directed to pay the assessed amount of alleged tax liability for Rs. 4,33,030/- for the Financial Year 2012-13, in pursuance of the Order dated 19.03.2018 (Annexure-1) passed by the Respondent No. 3, under Section 206C of ....

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....to pay the assessed amount of alleged tax liability for Rs.52,99,327/- for the Financial Year 2016-17, in pursuance of the Order dated 19.03.2018 (Annexure-1) passed by the Respondent No. 3, under Section 206C of the Income Tax Act, 1961, as the Respondent Department is not entitled to recover the said amount from the Petitioner, in view of the Judgment passed by the Hon'ble Supreme Court in the case of Ghanshyam Mishra and Sons Private Ltd. Vrs. Edelweiss Asset Reconstruction Company Ltd. reported in (2021) 9 SCC 657, wherein the Petitioner is also one of the Appellants. b) For quashing and setting aside the ex-parte Appellate Order dated 19.06.2024 (Annexure-5) passed by the Commissioner of Income Tax (Appeals), Kolkata under Secti....

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....ein the Petitioner is also one of the Appellants. b) For quashing and setting aside the ex-parte Appellate Order dated 19.06.2024 (Annexure-5) passed by the Commissioner of Income Tax (Appeals), Kolkata under Section 250 of the Income Tax Act, 1961, whereby the appeal dated 04.04.2018 (Annexure-3 Series) filed by the Petitioner challenging the Order dated 19.03.2018 (Annexure-1) passed by the Deputy Commissioner of Income Tax, TDS Circle, Ranchi (Respondent No. 3), under Section 206C of the Income Tax Act, 1961, for the Financial Year 2013-14, has been dismissed and the tax liability of Rs. 17,46,020/- created by him, has been confirmed against the Petitioner. c) For quashing and setting aside the Order dated 19.03.2018 (Annexure-1) p....

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....ncial Year 2015-16, has been dismissed and the tax liability of Rs. 50,30,722/- created by him, has been confirmed against the Petitioner. c) For quashing and setting aside the Order dated 19.03.2018 (Annexure-1) passed by the Deputy Commissioner of Income Tax, TDS Circle, Ranchi (Respondent No. 3), under Section 206C of the Income Tax Act, 1961, for the Financial Year 2015-16, whereby a tax of Rs. 50,30,722/- has been imposed/levied upon the Petitioner. W.P.(T) No.5161 of 2024 a) For quashing and setting aside the Notice of Demand dated 19.03.2018 (Annexure-2) issued by the Respondent No. 3, whereby the Petitioner has been directed to pay the assessed amount of alleged tax liability for Rs. 18,01,839/- for the Financial Year 2014-....