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TMI Blog2019 (6) TMI 1720X X X X Extracts X X X X X X X X Extracts X X X X ..... o 7 are lessees under writ petitioners and they are only formal parties as far as the instant writ petition is concerned. 2. Therefore, with consent of learned counsel for writ petitioner and the aforesaid Revenue Counsel, main writ petition itself is taken up, heard out and is being disposed of. 3. This matter turns on very narrow compass. 4. The case of the writ petitioner in a nutshell is that the second respondent viz., Jurisdictional Tax Recovery Officer of the Income Tax Department has issued six different notices. These notices have been sent to the aforementioned tenants/lessees of the writ petitioners. 5. The details of the six notices are as follows: S.No Date Reference No. 1 06.06.2019 TRC No.1728/TRO-8/CHE/2007-08 2 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... te Mr.P.N.Subramaniam. 10. Responding to this, learned Revenue Counsel submitted that under Section 226(3) of IT Act, it is open to the IT Department to proceed against the petitioners. It was submitted that IT Department will proceed against the other legal heirs also (who are available). 11. In other words, other legal heirs being available and having means, cannot be put against the IT Department to assail the impugned notices, is learned Revenue counsel's say. 12. Learned Revenue Counsel also pointed out that it is not as if the writ petitioners are not beneficiaries qua the aforesaid testament left by late Mr.P.N.Subramaniam. This Court again refrains from expressing any opinion or view on this aspect of the matter in the light ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t of a copy of this order. On disposing of the representation, the order disposing of the representation shall be served on each of the writ petitioners under due acknowledgement within seven working days from the date of disposal/order. The impugned notices shall, therefore, be kept in abeyance till the disposal of the representation of the writ petitioner dated 20.06.2019 in the aforesaid manner. If the outcome is in favour of the writ petitioners, that will be the end of the matter and the impugned notices will stand dropped. If the outcome is otherwise, the impugned notices shall be kept in abeyance for a further period of a fortnight from the date of communication of disposal of representation to the petitioner under due acknowledgemen ..... X X X X Extracts X X X X X X X X Extracts X X X X
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