2019 (9) TMI 1237

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..... o such notice under Section 226(3)(iii) of the Act has been served on the petitioner - Joint Account Holder of the Savings Bank Account, regarding which notice has been issued to the bankers. In view of the aforesaid, it is discernible that no notice issued under sub-section 3[ii] was forwarded to the petitioner which is sine qua non for the recovery of tax as provided under Section 226 of the Act .....

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..... Nine Crores Sixty One Lakhs Twenty Seven Thousand Three Hundred Twenty only) to respondent No.1 - Authority. 3. It is the contention of the petitioner that she has the Joint Savings Bank Account with her husband in respondent No.2 - Bank and the petitioner is the Primary Account Holder of the said Account. Notice has been issued by respondent No.1 to respondent No.2 for marking the said bank acc .....

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..... f the Savings Bank Account, regarding which notice has been issued to the bankers. 7. In view of the aforesaid, it is discernible that no notice issued under sub-section 3[ii] was forwarded to the petitioner which is sine qua non for the recovery of tax as provided under Section 226 of the Act. The mandatory requirement is not complied with by the revenue, in terms of Section 226(3)(iii) of the A .....

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