S. 226 : Collection and recovery – Stay of recovery -Garnishee proceedings -When an application for stay was pending before the Commissioner, attachment of bank accounts as per office Memorandum of Central Board of Direct Taxes, 15 Per Cent. of demand recovered from Assessee — Notices was quashed and set aside- However the claim of the assessee, seeking refund of the amounts attached pursuant to such directions, was not justified and could not be granted. [ S.226(3) ]
Sesa Resources Ltd. v. ACIT (2018) 408 ITR 527 (Bom) (HC)