- (1.) The subject matter of challenge in the instant writ proceeding is a letter dated 12th September, 2019, issued by the Deputy Commissioner of Income Tax, Central Circle, Meerut, addressed to the Principal Officer/Director, M/s Solitaire Foods Pvt. Ltd., New Delhi (being the writ petitioner before us). For convenience, the impugned letter is setout hereinbelow: "To, The Principal Officer/Director M/s Solitaire Foods Pvt. Ltd. 108, 1st Floor, No. 53, Hasanpur Village, Patpadganj, New Delhi. Sir/Madam, Sub:- Request for the Solitaire Foods Private Limited, (Pan: AALCS5930M) releasing/defreezing of account no.: C/A-272811100001963, Andhra Bank, Chander Vihar Market, Patpadganj, New Delhi-reg. Kindly refer to the above mentioned subject and your letter received in this office on 22.08.2019 on the above issues.
(2.) In this regard, I have been directed to convey you the observation of Pr. CIT(C), Kanpur letter F.No. Pr. CIT (C)/KNP/Stay of Demand/2019-20 dated 11.09.2019. I have been further directed to communicate you that your above bank account may be released subject to the following conditions:- (i). You make upfront payment of Rs. 20 lacs before 15 September, 2019. (ii). From October, 2019 you pay of monthly instalments of Rs. 7 lacs for period of 12 Months or decision of First Appeal, whichever is earlier.
(3.) In the light of the above, you are requested to make compliance of the above conditions by 15th September, 2019. It is strongly conveyed you that your request made for releasing/de-freezing of the above account may be considered only after compliance on your part of the above conditions. Yours faithfully, (Sunil Kumar Yadav) Deputy Commissioner of Income Tax Central Circle, Meerut According to the learned advocate for the petitioner, the impugned letter is contrary to the applicable CBDT circular, as contained under Instruction No. 1914, dealing with section 220 of the Income Tax Act, 1961-Collection and Recovery of tax-When tax payable and When assessee deemed in default-Recovery of Outstanding Tax demands.;