(1.) Petitioner has challenged demand notices dated 27.01.2016 and 28.01.2016 issued by the Deputy Commissioner of Income Tax, Ahmedabad, to the ICICI Bank, Ahmedabad, and Bank of India, Ahmedabad, seeking to recover the petitioner's unpaid tax dues of Rs. 30,56,76,000/ -through the petitioner's bank accounts in the said two banks. These orders are passed purportedly in the exercise of section 226(3) of the Income Tax Act, 1961, ('the Act' for short).
(2.) Brief Facts Are As Under.
(3.) Petitioner is a company registered under the Companies Act and is engaged in the manufacturing activities through its units. The petitioner is a sick industrial company within the meaning of section 3(1)(o) of the Sick Industrial Companies (Special Provisions) Act, 1985 ('SICA' for short) with effect from 30.09.2013. The company's case came to be registered on 27.06.2014 before the Board for Industrial and Financial Reconstruction ('BIFR' for short). According to the petitioner, such case is even now pending before BIFR.