Allowing the petition the Court held that the order of the Assessing Officer rejecting the stay petition filed by the assessee was non-speaking and merely made reference to the non-payment of 20 per cent. of the tax demand by the assessee. The order in question was unacceptable on all counts and was to be quashed in limine. The notices issued under section 226(3) to the assessee’s banks by the Assessing Officer were also quashed and the attachment of the bank accounts was lifted forthwith.