ALLAHABAD HIGH COURT · SOURCE-REVIEWED PROCEDURAL ORDER
Rahul Gupta v. Chief Commissioner of Income Tax and 3 Others
Writ Tax No. 606 of 2018 ·
Supplied court order; no reported citation stated
AO directed to decide pending section 220(6) application; no coercive steps until that decision.
Division Bench · Krishna Murari · Ashok Kumar
1. Facts of the case
The petitioner challenged a notice dated 1 February 2018 under section 221(1), pressing a demand of Rs.4,04,39,960 for AY 2015-16. Counsel stated that an assessment appeal was pending before CIT(A), Muzaffarnagar, and a section 220(6) application filed with the Assessing Authority on 27 March 2018 remained undecided.
2. Discussion by the Hon’ble Court
After hearing petitioner counsel Rishi Raj Kapoor and departmental counsel Manu Ghildyal and perusing the record, the Court addressed the pending application through time-bound directions. It did not decide the assessment dispute or the merits of the section 220(6) request.
3. Judicial decision
The writ was finally disposed of. Respondent No.2, the Assessing Authority, was directed to decide the 27 March 2018 application (annexure-7) within two weeks from production of a certified copy of the Court’s order. No coercive steps were to be taken against the petitioner until that application was decided.
4. Outcome / in whose favour
The petitioner undertook to place the certified copy before respondent No.2 within one week from the order date. The temporary protection ended at the application decision, not necessarily at disposal of the assessment appeal. The demand was not quashed by this order.
5. AKHB REVIEW POINT
Track the certified-copy production date and the subsequent application decision before assessing the duration of protection. Do not describe this as an indefinite stay, an allowed assessment appeal or an order granting the section 220(6) application. Sudha Gupta and Rahul Gupta are distinct petitioners, dockets and demand amounts despite matching directions.
Source and verification
Complete supplied one-page order read and visually inspected. Original SHA-256 independently reverified; full text matched the supplied review packet. AY 2015-16 is expressly stated; PAN is not stated. No later-proceedings or current-law clearance is claimed.
Source SHA-256: 92ee4d740dbf3743b7c6f066c786e4fdcc0574e4a3dcb5c2f274d34f8947abb0
Only provisions expressly identified in this order are recorded. No substantive tax merits or current statutory equivalence is inferred.
Source checked 2026-10-18. Later proceedings, compliance and current precedential treatment have not been comprehensively verified.
AI disclosure and professional disclaimer
This AKHB research note was prepared with AI assistance from an identified primary report. Independent human review is not represented.
General legal and tax research only; not legal or tax advice. Verify the complete judgment, applicable statutory version and subsequent treatment before reliance. The AKHB REVIEW POINT is editorial analysis, not the Court’s holding. No current-law clearance is claimed.