Sec. 220 & 226 of the Income-tax Act, 1961 - Collection and recovery of tax - The appellant suffered assessment order for the assessment years 2012-13, 2013-14, 2015-16, 2016-17 and 2017-18 aggregating to a sum of Rs. 54,08,05,243/-. Before filing an appeal, the appellant had approached the AO, and submitted a representation to stay of the operation of the assessment orders dated 25-12-2019. The respondent informed that the stay petition can be considered only on payment of minimum of 20% of total demand. This order was challenged by the appellant in W.P (MD) No. 3544 of 2020. The appellant agreed to pay 20% of the demand on instalments. The Ld. Judge granted time to pay 20% of the amount in five instalments. However, prior to this, the AO passed the attachment in terms of Section 226(3) of the Act. Therefore, the petitioner could not operate the banks accounts. Thus, in appeal, the court inclined to modify the order by lifting the order of attachment subject to the appellant paying amount in instalments saying that upon payment of the fifth installment on 30-7-2020, there shall be absolute stay. - DHANALAKSHMI SRINIVASAN CHIT FUNDS P. LTD. V/s PR. CIT - [2020] 274 TAXMAN 045 (MAD)