Pursuant to orders u/s 201(1) & 201(1A), the assessee was liable to
make payment of Rs. 59.06 crores for
three years. The AO rejected the stay application and directed that 50% of the demand be paid. A part of the demand was paid by the assessee. The assessee filed a stay application before the CIT. Of the three years, the CIT granted stay for two years and directed the AO to realize the demand for AY 2010-11 amounting to Rs. 7.69 crores. No reasons were given for the decision.
Despite the stay granted by the CIT, the AO issued garnishee notices u/s 226 (3) for the entire amount of Rs. 59.06 crores.