Dishnet Wireless Limited and Aircel Limited filed writ petitions challenging the proceedings initiated by the Income Tax Department under Section 201(1) and 201(1-A) of the Income Tax Act for alleged failure to deduct Tax Deducted at Source (TDS) on certain foreign remittances. The petitioner-companies argued that the National Company Law Tribunal (NCLT), Mumbai, had admitted their applications and initiated Corporate Insolvency Resolution Process (CIRP), declaring a moratorium under Section 14 of the Insolvency and Bankruptcy Code (IBC). They contended that the proceedings by the Income Tax Department were in violation of the moratorium. The Income Tax Department argued that the time limit for assessment had not expired and that they were not taking any coercive

Dishnet Wireless Limited and Aircel Limited filed writ petitions challenging the proceedings initiated by the Income Tax Department under Section 201(1) and 201(1-A) of the Income Tax Act for alleged failure to deduct Tax Deducted at Source (TDS) on certain foreign remittances. The petitioner-companies argued that the National Company Law Tribunal (NCLT), Mumbai, had admitted their applications and initiated Corporate Insolvency Resolution Process (CIRP), declaring a moratorium under Section 14 of the Insolvency and Bankruptcy Code (IBC). They contended that the proceedings by the Income Tax Department were in violation of the moratorium. The Income Tax Department argued that the time limit for assessment had not expired and that they were not taking any coercive