High Court of Judicature at Madras · Judgments and reasoned final orders
Sri Sankar Jewellery (Rep. by Partner S. Shankarlingam) v. CIT(A), Faceless Appeal Centre & Ors.
W.P.(MD) No. 31598 of 2025 ·
Post-search appeals for AYs 2017-18 to 2021-22 and bank account attachment: NFAC directed to decide pending appeals within 6 months and fresh stay petition within 6 weeks, with liberty to move AO under section 220(6).
1. FACTS OF THE CASE
Following a search operation and adverse assessment orders for AYs 2017-18 to 2021-22, the petitioner filed appeals before the CIT(A), Faceless Appeal Centre on 15.04.2025 and approached the High Court seeking time-bound disposal of the appeals and release of five attached bank accounts maintained with Karur Vysya Bank and State Bank of India.
2. DISCUSSION BY THE COURT
Without entering into the merits, the Single Judge directed the first respondent (CIT(A), NFAC) to dispose of the appeals within six months and granted the petitioner liberty to file a fresh stay petition before the CIT(A) to be disposed of within six weeks, observing that lifting of the bank account attachment would depend on the interim order or a section 220(6) application before the Assessing Officer.
3. JUDICIAL DECISION
Disposed of W.P.(MD) No. 31598 of 2025 with timelines of 6 months for appellate disposal and 6 weeks for stay petition disposal.
4. OUTCOME
Mixed / Procedural direction - NFAC directed to dispose of appeals within 6 months and stay application within 6 weeks; lifting of bank attachment made dependent on interim order or section 220(6) application.
5. AKHB REVIEW POINT
AKHB analysis: before seeking a writ of mandamus to lift bank attachments under section 226(3) during a pending first appeal, ensure that a formal stay application under section 220(6) before the AO and an appellate stay petition before NFAC have been filed and pressed.
Source and verification
4-page official High Court of Judicature at Madras judgment PDF (20251106_HCMD011564772025.pdf).
Original PDF: 4 pages · SHA-256: bfc1e7f39a2277519d52a0e2ecbe4098690e70ef6fdaca1c1890d28f1676ac8d
Supplied source-reviewed note retained; original bytes and identity validation checked in this release. Substantive re-review is not claimed for this record.
Applies sections 220(6) and 250 of the Income-tax Act, 1961 for AYs 2017-18 to 2021-22. Income-tax Act, 2025 equivalence is not verified.
Full primary judgment PDF read page-by-page and verified against the AKHB Google Drive repository. Comprehensive subsequent judicial treatment has not been independently verified.
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General research only. Read the complete judgment and verify applicable law and subsequent treatment before reliance.