Dismissing the petition the Court held that notices issued under section 226(3) without challenging the demand made under section 201(1A) was not maintainable. The assessee was not aggrieved by the demand for the outstanding tax with interest and penalty for which intimation under section 200A(1) had been given to the assessee. The assessee was only aggrieved by the notices under section 226(3) calling upon the assessee’s bank to make the deposit of the outstanding liability standing against the assessee. Section 201 was prima facie not attracted. The Department had found discrepancy on account of deduction of tax at source on the salary component and, accordingly, on the basis of voluntary return filed by the assessee along with statement of tax deduction at source had given intimation under section 200A(1) to the assessee. Since the assessee did not respond to the intimation of demand given by respondent No. 3, the intimation under section 200A(1) was treated as a notice of demand. There was failure on the part of the assessee to meet the demand and deposit the outstanding tax. Accordingly, notice under section 226(3) was issued. The assessee was within its rights to file a statutory appeal under section 246A before the Commissioner (Appeals) and therefore, could not straightaway approach the court invoking extraordinary writ jurisdiction under article 226 of the Constitution of India. There was an inseparable causal connection between the intimation of demand under section 200A(1) and recovery proceedings under section 226. Directed to file an appeal before CIT(A)  (AY.2007-08 to 2015-16)