The case involves Rajesh Kumar Makhijani, the petitioner, who filed a writ petition under Article 226 of the Constitution of India against various income tax authorities, including the Union of India through the Secretary of the Central Board of Direct Taxes, and several commissioners of income tax. The petitioner sought relief from the High Court of Chhattisgarh at Bilaspur to restrain the fourth respondent from invoking coercive recovery measures pending the disposal of his appeals against the assessment orders. The petitioner argued that the appeals were pending before the Commissioner of Income Tax (Appeals) and had not been decided, yet coercive recovery measures were being threatened.
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