The appeals filed by the Department and cross-objections filed by the assessee were pending before the Tribunal. However, only an amount was recovered from the assessee’s bank account. During pendency of the appeals and cross-objections before the Tribunal, the assessee filed a stay application before the PCIT who directed the assessee to pay 50 per cent. of the demand for considering his stay till disposal of the appeals. The assessee did not comply with his order. On a writ petition contending that as his properties including the stock-in-trade were attached, his business activities were completely jeopardized and hence he was unable to generate any revenue for payment of the tax dues. Court held that the attachment of the stock-in-trade of the assessee should be withdrawn to enable him to pay the tax dues in terms of the first proviso to section 254(2A). In view of the statement made by the Department itself that not much money could be appropriated through attachment of the bank accounts, attachment of the bank accounts could be withdrawn. The assessee should deposit 20 per cent. of the tax dues following the order passed by the first appellate authority. On such deposit, attachment of assessee’s bank accounts and the stock-in-trade should stand withdrawn forthwith. However, post-withdrawal of attachment if the assessee deposited any amount into the bank accounts, the bank authorities should ensure that 50 per cent. of such deposit was maintained in the accounts till such time as was considered necessary. (AY.2007-08, 2008-09, 2009-10)