Assessee, a civil contractor, builder and developer, had been granted several contracts by statutory authorities for poor and economically weaker sections of society under Prime Minister Awas Yojana.  During reassessment proceedings, additions were made on account of bogus purchases in hands of assessee. All bank accounts of assessee had been attached by garnishee proceedings under section 226(3) of the Act.  Before the Tribunal the  Assessee submitted that it had already paid tax component and balance outstanding demand represented interest and penalty only and sought for vacation of garnishee proceedings contending that it was not in a position to pay its labourers. Tribunal held that since assessee was not in a position to clear dues of its workers due to attachment of its bank accounts and debtors, in view of COVID-19 pandemic, it would be fit and proper to grant stay on collection and recovery of remaining outstanding demand. (AY. 2010-11)