TMI Blog2024 (3) TMI 155X X X X Extracts X X X X X X X X Extracts X X X X ..... 3980 & 3982 of 2024 - - X X X X Extracts X X X X X X X X Extracts X X X X ..... ame to be issued under Section 271 DA of the Income-tax Act imposing penalty of Rs. 2,57,00,000/-, which is equivalent to the amount remitted into the petitioner's accounts, for violation of Section 269 ST of the Income-tax Act. This was followed by the impugned attachment notices. Meanwhile, the petitioner had filed an appeal on 05.03.2022 before the Commissioner of Income-tax (Appeals). 3. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e concluded in the appeal and that the appellate authority reserved orders on 09.02.2024. In the above facts and circumstances, learned senior counsel submits that the attachment of the petitioner's bank accounts has gravely prejudiced the petitioner and that the petitioner is unable to disburse payments for the various purposes indicated in paragraph 4 of the additional affidavit dated 19.02. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... opriate to record definitive conclusions on the issues raised in the said order. However, the petitioner has placed on record evidence that prima facie indicates that the receipt of Rs. 2.57 crore was under Cheque No.119160 issued by M/s.Golden Vats Private Limited. If the petitioner is able to satisfy the appellate authority that the said remittance was indeed made by a cheque, the order imposing ..... X X X X Extracts X X X X X X X X Extracts X X X X
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