The assessment was completed adding the amount deposited in bank as income of the assesseee. The assessee filed an application for stay of recovery. The Assessing Officer directed the assessee  to deposit 20 percent of tax in dispute  relying on circular dated July 31 st, 2017 (2017) 396 ITR 55 (St). The Assessing Officer also attached Bank accounts of the assessee by issuing notice u/s 226(3) of the Act. On writ the Court held that the assessee was required to be heard, and there should be due application of mind before a decision is taken on the prayer for stay. The order did not indicate or disclose any application of mind on the part of the respondent in considering the prayer of the assessee. The order was not valid. Directed to withdraw the attachment of Bank accounts forthwith. (AY.  2018-19)