JUDGMENT :

C. SARAVANAN, J.

Prayer: Petition filed under Article 226 of the Constitution of India to issue a Writ of Certiorarified Mandamus calling for the records of the impugned order dated 11.10.2021 vide DIN and Letter No. ITBA/COM/F/17/2021-2022/1036304326(1) passed by the second respondent and quash the same and direct the respondents to stay the recovery of tax demand until the disposal of the appeal by the Commissioner of Income Tax (Appeals).

1. The petitioner has challenged the impugned order dated 11.10.2021 passed by the second respondent, the Deputy Commissioner of Income Tax under Section 220(6) of the Income Tax Act, 1961 (hereinafter referred to as the IT Act).

2. The learned counsel for the petitioner submits that an Assessment Order came to be passed by the first respondent on 18.12.2019 for the Assessment Year 2017-2018. Under these circumstances, the petitioner had also preferred an appeal before the Commissioner of Income Tax (Appeals) under Section 246(A) of the IT Act, 1961.

3. The learned counsel for the petitioner further submits that the appeal was also taken up for hearing before the Commissioner of Income Tax (Appeals) and a written submission was filed by t