Petitioner, a multi-state scheduled urban cooperative bank was by three separate notices under section 226(3) called upon to forthwith pay any amount held by it in accounts of three assessee’s viz. M, S and N due to Deputy Commissioner on account of income-tax, wealth-tax,/Interest/Penalty. Petitioner informed Deputy Commissioner that they had marked a ‘Debit freeze’ for stated accounts. Subsequently, petitioner was declared as an ‘assessee-in-default’ for non-compliance with notice under section 226(3) and RBI was called upon to attach all bank accounts, FDs, RDs, and other deposits held by petitioner to effect recovery of dues from ‘S’ in respect of arrears of income-tax. On writ the Court held that impasse between the petitioner and Deputy Commissioner could be resolved by directing petitioner to forthwith remit electronically a sum of Rs. 43 crores to Deputy Commissioner. Upon such remittance, petition was to be disposed of and impugned notice and impugned order were to be quashed and set aside and all further action in respect thereof would be prohibited.