On a writ petition to lift the attachment of the bank accounts the Court held  that since a statutory appeal was filed against the order issued under section 271DA of the Act it was not appropriate to record definitive conclusions on the issues raised in the order. The assessee was directed to remit a sum of Rs. 12.5 lakhs as a condition for raising the attachment of its bank accounts. Immediately upon receipt of such sum, all attachment orders in question would stand raised and the assessee would be free to operate its bank accounts. This order was subject to the outcome of the appellate proceedings.