S. 201 : Deduction at source – Failure to deduct or pay – Earlier order was set aside by the Tribunal -Department appeal is pending for hearing – Order of Tribunal not stayed – Order holding that the assessee in default for latter year following the order of earlier year was quashed – Order of Tribunal is binding on the Assessing Officer – Order treating the assessee in default was quashed . [S. 260A, Art , 226 ]