THE HONOURABLE SRI JUSTICE P.SAM KOSHY AND THE HONOURABLE SRI JUSTICE NARSING RAO NANDIKONDA W.P.No.17123 OF 2025 ORDER : (per Hon’ble Sri Justice P.Sam Koshy)

Heard Mr. A.V.A.Siva Kartikeya, learned counsel for the petitioner and Ms.B. Sapna Reddy, learned Senior Standing Counsel for the Income Tax Department for respondent Nos.1 to 6.

Perused the record.

2. The present writ petition has been filed assailing the order dated 02.12.2024 rejecting the stay application of the petitioner, pending disposal of the appeal before the first Appellate Authority for the assessment year 2018-19 and the garnishee notice issued by respondent No.1 dated 29.04.2025 to respondent No.7 i.e., the banker of the petitioner.

3. The petitioner herein had filed statutory remedy of an appeal under Section 246A of the Income Tax Act, 1961 (for short, the ‘Act’) before the Appellate Authority along with the Memo of Appeal. The petitioner had also preferred interim protection so far as the recovery proceedings are concerned under Section 220(6) of the Act. It is this application which stands decided by the impugned order.

4. The contention of the learned counsel for the petitioner is that the assessment order dat