Allowing the petition the Court held that when the liability itself was questioned and was the subject matter of appeals before the court and the appeals were reserved for orders recovery of dues for the assessment years 2003-04 to 2007-08 was not justified, as the issue had to be finally decided by the court. For the assessment year 2008-09 the assessee had not obtained any stay from the first appellate authority and the balance due payable by the assessee was Rs.83,16,190. The assessee was directed to pay a sum of Rs. 15 lakhs towards the assessment year 2008-09 for the purpose of lifting the garnishee orders and this was to be without prejudice to either parties in the appeal before the first appellate authority. On failure to make the payment within the stipulated time the orders were to be restored automatically. (AY. 2003-04 to 2008-09 )