Silicon Graphics Systems (India) Pvt. Ltd. v. PCIT (2021) 438 ITR 397 (Delhi)(HC)

S. 226 : Collection and recovery-Modes of recovery-Appeal effect to orders-direction was issued to cancel the demands and also issue refunds with interest. [S. 244A, 271(1), Art. 226]

The assessee filed writ petition seeking directions to the Principal Commissioner to pass orders to implement the orders of the Commissioner (Appeals) and the Tribunal for the assessment years 1995-96, 2005-06, 2006-07 and 2008-09 and cancel the demands and also for refund for the assessment year 2003-04 together with statutory interest under section 244A of the Income-tax Act, 1961 as the penalty imposed under section 271(1)(c) had been quashed by the Tribunal. High Court directed respondent No. 2 to decide the applications and letters by way of a reasoned order after giving an opportunity of hearing to the assessee. ( AY. 1995-96, 2003-04, 2005-06, 2006-07 and 2008-09)