An assessment order was passed  raising the demand. The assesssee filed a petition for stay of demand before Assistant Commissioner who allowed stay petition on payment of 20 per cent of tax demand. High Court permitted assessee to pay 20 per cent of demand in five instalments.  However, an order of attachment was passed by Principal Commissioner in terms of section 226(3) so as to insist assessee to pay such 20 per cent of tax demand. Thereafter, impugned order was modified holding that impugned attachment would be lifted on pursuant to payment of first instalment of 20 per cent of tax demand  On writ the Court held that attachment order passed so as to insist assessee to pay an instalment of 20 per cent tax demand would result in denial of benefit originally conferred upon assessee of allowing stay of demand on payment of 20 per cent of tax, therefore, impugned order of attachment was unjustified and same was to be set aside. (AY. 2012-13, 2013-14, 2015-16 to 2017-18)