2025 (5) TMI 1184

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....etitioner has questioned the rejection of refund of recovered amount during the pendency of the appeal by order dated 22.01.2025 with respect to assessment year 2016- 17 (corresponding to financial year 2015-16). 3. The petitioner, registered Co-operative Society, engaged in facilitating credit services and collection of deposit and giving loans exclusively to its members, has been assessed to tax treating cash deposit of Rs. 2,10,44,000/- in the Allahabad Bank Account as unexplained during the financial year 2015-16 relating to assessment order 2016-17. Assessment was undertaken under Section 147 by issue of notice under Section 148 of the Income Tax Act ("I.T. Act", for short). Treating the entire aforesaid deposit as unexplained cash ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ing circular issued by Central Board of Direct Taxes (CBDT) to be followed by the Assessing Officer for the purpose of invocation of Section 220 of the I.T. Act, though application was made with prayer to refund the amount so recovered beyond 20% of the demand, the said authority in clear violation of the same rejected the request for refund of recovered amount without taking into account order of stay granted by the Principal Commissioner of Income Tax, Bhubaneswar-I by order dated 22.01.2025. He submitted that during pendency of appeal in consideration of application for stay of demand, the Principal Commissioner of Income Tax, Bhubaneswar-I directed the Assessing Officer to lift attachment by granting full stay of demand till disposal of....