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TMI Blog2019 (12) TMI 508X X X X Extracts X X X X X X X X Extracts X X X X ..... would be to the extent of ₹ 45 crores (as against the proposals for provisional attachment where it was mentioned that a sum of ₹ 22 crores odd was unaccounted under different heads (in all three petitions)). - CM-18138-2019 in/and CWP-31069-2019 (O&M), CM-18134-2019 in/and CWP-32683-2019 (O&M), CM-18143-2019 in/and CWP-32702-2019 (O&M) - - - Dated:- 2-12-2019 - HON'BLE MR.JUSTICE AJAY TEWARI And HON'BLE MR. JUSTICE VIVEK PURI Mr. Pankaj Jain, Sr. Advocate with Mr. Sachin Bhardwaj, Advocate for the petitioner Mr. Rajesh Katoch, Sr. Standing counsel with Ms. Pridhi Jaswinder Sandhu, Advocate for the applicants-respondent ORDER Ajay Tewari, J. ( Oral ) CM-18132 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e petitioners undertakes to supply a copy of the paper book to the opposite counsel during the course of the day. Main cases By these three petitions (pertaining to the same group) the petitioners have challenged the provisional attachment of 1300 flats by the Revenue. On 25.10.2018 a search under Section 132 of the Income Tax Act, 1961, was conducted in the business premises of the petitioners (i.e. almost 375 days ago) and after analysing of seized documents alongwith findings of search detailed in appraisal report which was received in the office of Deputy Commissioner of Income Tax, Central Circle-2, Ludhiana, the impugned provisional attachment of property was sought. As per the proposal for provisional attachme ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 322 ITR 0688 whereas per him, in a similar case provisional attachment of stock in trade was upheld. We find that the facts are completely dis-similar. In that case one property each of the two petitioners was attached and not their entire stock in trade. On the last date, we had requested the learned counsel for the respondent No.9 to indicate whether after this more than one year, the Revenue can give us a ball park figure or at least the maximum figure which it may ultimately feel that it would have to recover, but beyond relying upon the abovesaid three arguments, he states that it is not possible for the Revenue to quantify the figures before completion of the assessment. In our opinion, it is a sta ..... X X X X Extracts X X X X X X X X Extracts X X X X
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