Vibhu Bakhru, J.

1. This is a writ petition filed by the petitioners challenging the order dated 01.02.2013 passed by Respondent no.1 (hereinafter referred to as the “Assessing Officer”) and the consequential notice dated 04.02.2013 issued under Section 226(3) of the Income Tax Act,1961 (hereinafter referred to as the "Act"). The petitioners are aggrieved on account of the action of the Assessing Officer in appropriating a sum of Rs.95,85,30,934/- which was lying in escrow with respondent No.2 bank.

2. The petitioners held shares in respondent No.3 company, namely, scorts Heart Institute & Research Centre Ltd. (hereinafter referred to as the “assessee company”). Petitioner Nos.1 & 2 held 1,00,000 shares each of the assessee company and the petitioner No.3 held 16,00,000 shares of the assessee company. The petitioners along with three other entities, namely Charak Ayurvedic Institute, Escorts Employees Welfare Trust and Diamond Leasing and Finance Limited who held 100 shares of the assessee company each entered into a share purchase agreement dated 25.9.2005 for sale of their shares in the assessee company to M/s Fortis Health Care Ltd. (hereinafter referred to as the “pu