IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED : 03.02.2026 Coram The Honourable Mr.Justice C.Saravanan and W.M.P.No.47310, 47312, 47315 & 47317 of 2025 NAGAPPAGOUNDER SAPPANIPATTI IYAPPAN ..Petitioner in both W.Ps.

Vs.

1 INCOME TAX DEPARTMENT O/o.THE INCOME TAX OFFICER WARD 1 DHARMAPURI

2 INCOME TAX DEPARTMENT National Faceless Assessment Centre Delhi

3 INDIAN BANK

6 Yercaud Road Hastampatti Salem 636 007.

..Respondents in both W.Ps.

Prayer in W.P.No.42276 of 2025 Writ Petition filed under Article 226 of the Constitution of India praying for the issuance of a Writ of Certiorari to call for records pertaining to the impugned order issued by the 2nd Respondent vide reference No. ITBA/AST/S/147/2021-22/1041693874(1) dated 26.03.2022 demanding Rs.1,55,10,000/- One crore fifty five lakhs ten thousand only and consequent impugned Notice issued by the 1st Respondent to 3rd Respondent vide reference No.ITBA/RCV/S/226(3)_1/2022- 23/1050035187(1) dated 23.02.2023 towards attachment of Petitioner’s bank account A/c.No. 10006711436 demanding Rs.4,15,97,609/- (Four Crore fifteen lakhs ninety seven thousand six hundred and nine only and to quash the same.

Prayer in W.P.No.42291 of 2025 Writ Petition filed under Article 226 of the Constitution of India praying for the issuance of a Writ of Certiorari to call for records pertaining to the impugned order issued by the 2nd Respondent vide ITBA/AST/S/147/2021-22/1041693959(1) dated 26.03.2022 demanding Rs.1,71,11,680/- (One crore seventy one lakhs eleven thousand six hundred and eighty only) and consequent impugned Notice issued by the 1st Respondent to 3rd Respondent vide reference No.ITBA/RCV/S/2263_1/2022-23/1050035187(1) dated 23.2.2023 towards attachment of Petitioners bank account A/c.No.10006711436 demanding Rs.4,15,97,609/- Four Crore fifteen lakhs ninety seven thousand six hundred and nine only and quash the same.

For Petitioner in both W.Ps. : Mr.P.Murugesan For Respondents 1 and 2 in both W.Ps. : Mrs.M.Sheela Senior Standing Counsel and Mr.H.Siddharth Standing Counsel

Common Order

By this Common Order, both these Writ Petitions are disposed of.

2. In Writ Petition No.42276 of 2025, the Petitioner has challenged the Assessment Order dated 26.03.2022 passed by the second Respondent under Section 147 read with Section 144 and 144B of the Income Tax Act (in short, Act) for the AYs 2014-15 and Penalty Notice dated 23.02.2023 under Section 226 (3) of the Act issued by the first Respondent to the third Respondent, whereby, the Petitioner's bank account was attached for a sum of Rs.4,15,97,609/- for the Assessment Years 2014-2015 and 2015-2016.

3. In W.P.No.42291 of 2025, the Petitioner has challenged the Order dated 26.03.2022 passed by the second Respondent for the Assessment Year 2015-16 under Section 147 read with Section 144 read with Section 144B of the Act and the consequential demand Notice issued under Section 226 (3) of the Act dated 23.02.2023 for a sum of Rs.4,15,97,609/- for the aforesaid Assessment Years.

4. The Petitioner failed to file Return of Income for the said Assessment Years despite Section 148 notice and subsequent notices under Section 142 (1) of the Act were issued and thus suffered the impugned Orders.

5. The Petitioner was also issued with a consequential penalty Order dated 28.09.2022 under Section 271 (1) (c) of the Act, wherein, Penalty of Rs.52,71,849/- was imposed on the Petitioner pursuant to a Notice dated

15.09.2022.

6. The Petitioner is a Small Time Operator engaged in the sale of Animal Feed Supplements and that entire turnover of the Petitioner has been assessed as taxable income of the Petitioner in the absence of Return of Income being filed by the Petitioner.

7. The learned counsel for the Petitioner prays for remand of the matter for fresh adjudication. The learned counsel for the Petitioner further submitted that the Respondent has also party recovered a sum of Rs.3,70,206/- towards tax liability and penalty as confirmed in the impugned Assessment Orders.

8. The