The petitioner is a trust esatblshed under Indian Trust Act 1882 and granted a  certificate of registration by the SEB  as venture capital Fund and the petitioner is entitle exemption u/s 10 (23FB) of the Act. Earlier years the Appellate Tribunal decided the issue in favour of the asseee and the assesse is entitle to huge amount of refunds. When the stay application was pending vefore the CIT, The AO passed provisional attachment u/s 281B of the Act, attached the Bank Accounts u/s. 226(3) of the Act and also adjusted theb refunds u/s. 245 of the Act. On writ the Court  held that  revenue authorities  should apply the law equally to all and not be over zealous in seeking to collect revenue ignoring the statutory provisions as well as binding decisions. The petitioner is being singled out for unfair treatment. Accordingly recovery proceedings were stayed. Revenue was directed to re deposit the amount with drawn from the Bank. Order set aside. Court also observed as under “we have to express our dismay at the conduct of the Officers of the Revenue in this matter. We pride ourselves as a State which believes in rule of law. Therefore, the least that is expected of the Officers of the State is to apply the law equally to all and not be over zealous in seeking to collect the revenue ignoring the statutory provisions as well as the binding decisions of this Court.” Revenue was also directed to pay cost of Rs.50,000 to the Petitioner for the unnecessary harassment. (WP No. 543 of 2019, dt. 26.03.2019) (AY. 2016-17).