The AO disallowed the expenses u/s 60 , 63 of the Act and raised the demand on the assessee. The appeal is pending before the CIT (A) . The AO issued garnishee notices to the Directors u/s 179 of the Act . When the appeal was pending the revenue issued notice u/s 179 of the Act to the Directors . On writ the High Court directed the CIT(A) hear the appeal with on four weeks from the date of the receipt of an authenticated copy of the order. Stay proceedings were stayed . UTI Mutual Fund v ITO ( 2012) 345 ITR 71 ( Bom) (HC) WPNo. 228 of 2020 dt 24 -01-2020 )
Teleperformance BPO Holdings Pvt Ltd v ACIT ( Bom) (HC) ( UR)
S.226: Collection and recovery – Modes of recovery –Pendency of appeal before CIT(A) – CIT(A) is directed to hear the appeal with on four weeks from the date of the receipt of an authenticated copy of the order- Stay proceedings were stayed . [ S. 179, 226(3) ]