COMMON ORDER

In both these writ petitions, orders of attachment of the petitioner's bank accounts are challenged.

2. The petitioner runs educational institutions under the name and style of 'Kings College of Engineering' and 'Queens College of Arts and Science for Women'. The petitioner Trust is registered under Section 12-A of the Income-tax Act, 1961 (the Income-tax Act) and a certificate has also been issued under Section 80 G thereof to the petitioner. The matter pertains to the receipt of a sum of Rs.2,57,00,000/- from M/s.Golden Vats Private Limited on 02.05.2017. On the suspicion that the said amount was received as cash, a notice under Section 143(2) of the Income-tax Act and a subsequent notice under Section 142(1) were issued to the petitioner in 2019. The petitioner responded to such notices and pointed out that the amount was received as donation under Cheque No.119160 dated 02.05.2017. Eventually, an order dated 05.02.2022 came to be issued under Section 271 DA of the Income-tax Act imposing penalty of Rs.2,57,00,000/-, which is equivalent to the amount remitted into the petitioner's accounts, for violation of Section 269 ST of the Income-tax Act. This was followed by t