Bhaskar Bhattacharya, J. - (1.)By this writ application, the writ petitioner has prayed for setting aside notice dated January 16, 2003, under Section 226(3) of the Income-tax Act, 1961 (the "Act"), issued by respondent No. 1 for realisation of the demanded amount from the different persons who are holding money for or on account of the petitioner.
(2.)The petitioner is an assessee under the Act. The petitioner received a notice dated February 15, 2000, under Section 158BC of the Act from the office of the Joint Commissioner of Income-tax, Special Range-8, directing the petitioner to submit a return for the block period, viz., 1989--December 2, 1999. Pursuant to such notice, the petitioner submitted a return on March 30, 2000, under protest.
(3.)Ultimately, the petitioner was assessed and on December 31, 2000, a demand of Rs. 2,29,50,263 was raised. Subsequently, the petitioner came to know from his bankers that respondent No. 1 had issued purported notices under Section 226(3) of the Act asking the various banks to pay money deposited in the petitioner's account to the said respondent pursuant to the demand against the petitioner. The petitioner challenged those notices before this court under article 226 of the Constitution of India and Dilip Kumar Seth J., by order dated May 10, 2002, quashed those garnishee notices and directed the respondents to repay the amount debited from the petitioner's account.
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