S. Muralidhar, J.

1. The Petitioner, Securitrans India Pvt. Ltd. (‘SIPL’), has filed this writ petition against the Income Tax Department (‘hereinafter referred to as ‘the Department’) [Respondent Nos. 2 to 6] seeking various reliefs including the release of a sum of Rs. 60,48,672 which was seized while transporting cash from the customers of HDFC Bank [Respondent No.7] to its Gandhi Nagar Branch at Ghaziabad.

Background facts

2. The background to the petition is that the Petitioner-SIPL is engaged in the business of transporting cash on behalf of the banks in its armoured vehicles including cash collections from customers of the various banks. In the instant case, SIPL carries out the service of collection and safe delivery of money physically from the customers of Respondent No. 7/HDFC Bank strictly in accordance with the terms of a written agreement entered into between SIPL and HDFC Bank. The Petitioner states that it is also a registered service provider and pays service tax. It is stated that under the Finance Policy of the Government of India, the business carried by