TMI Blog2020 (6) TMI 412X X X X Extracts X X X X X X X X Extracts X X X X ..... ay or simple prayer for stay along with the pending appeal ought to have been preferred before the 2nd respondent. Be that as it may, the petitioner has undertaken to file the application for stay and as there is lock down owing to the COVID 19, pandemic, grant three weeks time to the petitioner to file the application for stay before the 2nd respondent. In case such application is filed, the 2 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... come as ₹ 37,84,262/- and raised a demand of ₹ 47,35,787/-. The petitioner was also served with a notice under Section 142(1) by the 1st respondent ie., the assessment order, Ext.P1 dated 3.12.2019. Aggrieved by Ext.P1 order, as rectified by Ext.P1(a), the petitioner preferred an appeal, Ext.P2 before the respondent, Commissioner of Income Tax (Appeals), Kowdiar, Thiruvananthapuram. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... opher Abraham, learned counsel appearing on behalf of the Income Tax Department submits that the necessity to issue garnishee notice was on account of the fact that the petitioner neither filed the return nor gave an explanation with regard to deposit and the Government's revenue had to be recovered in the manner as noticed above in case the assessee fails to pay off the same. 4. Having hea ..... X X X X Extracts X X X X X X X X Extracts X X X X
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