Boang Technology Pvt Ltd Vs ACIT (Delhi High Court)
The Delhi High Court, in the case of Boang Technology Pvt Ltd Vs ACIT, addressed an urgent petition challenging the income tax department’s immediate freezing of multiple bank accounts following the rejection of a stay application. The petitioner sought the quashing of the Assessing Officer’s (AO) order rejecting the stay of demand (dated September 23, 2025) and the subsequent attachment notice issued under Section 226(3) of the Income-tax Act, 1961 (dated September 24, 2025).
The Procedural Challenge
The core grievance raised by the petitioner was that the AO, after rejecting the request for stay of the outstanding tax demand, immediately proceeded to freeze thirteen bank accounts held at HDFC Bank. This action was taken without allowing the petitioner any time or opportunity to approach the higher appellate authority, the Commissioner of Income Tax (CIT), to challenge the AO’s rejection. The petitioner argued that the freezing of its accounts caused great prejudice, impeding its ability to pay employee salaries and meet statutory obligations. The matter was listed urgently before the Chief Justice.
High Court’s Conditional Resolution
The High Court achieved a resolution by accepting a conditional proposal presented by the Senior Standing Counsel (SSC) representing the Revenue. The Revenue submitted that if the petitioner deposited 20% of the disputed demand, the attached accounts would be released immediately.
