S.225 :Collection and recovery -Stay of proceedings – Pendency of first appeal – Bank account cannot be attached without giving a reasonable opportunity of hearing – Attachment of bank account was set aside – Assessing Officer must objectively decide the application for stay considering that an appeal lies against his order – The matter must be considered from all its facets, balancing the interest of the assessee with the protection of the Revenue.- Directed to hear the stay application with in six weeks from the date of the order [ S. 226 , 250, Art . 226 ]