(1.) BY this writ petition the prayer has been made for quashing the order dt. 22nd Nov., 1999 (Annexure 16) passed by the CIT (Tax Recovery), Agra, purported to have been passed under r. 86(1) of the Second Schedule to the IT Act, 1961 ('the Act').
(2.) I heard Shri Rajesh Kumar, the learned counsel for the petitioner as well as Shri A.N. Mahajan, the learned standing counsel for the respondents.
(3.) THE learned counsel for the petitioner, Shri Rajesh Kumar, has contended that the order dt. 2nd July, 1997 passed by the TRO is not conclusive order but it is original order against which the appeal lies under r. 86(1) of the Second Schedule is as below :