This order is passed in the peculiar facts and circumstances of the petitioner’s case and only because Mr. Agarwal informs us that the CIT(A) has scheduled the matter for hearing shortly. In fact, he has heard it in part. It is, therefore, clear that when the appeal is being heard, the demand is raised on the petitioner/assessee by treating him as an assessee-in-default. We have passed this order so that the petitioner can avail of his right of appeal. In ordinary circumstances, we would have relegated the petitioner to the remedy of making an application for stay before the CIT(A) and thereafter left it to the CIT(A) to take an appropriate decision thereon. However, since the appeals are being heard, we have passed this order. This order cannot be treated as a precedent for all cases of this nature. We direct that during the pendency of the above appeals, the attachment, if any, levied on the petitioner’s bank account to stand raised forthwith. However, this is without prejudice to the power conferred in the Revenue/Department to collect and recover taxes, which are due and payable. We record the statement made by Mr. Agarwal on instructions as an undertaking to this Court and to this effect that during the pendency of the appeals before the CIT(A), the petitioner shall not dispose of or create third party right in respect of his movable assets and properties. This, however, shall not prevent the petitioner/assessee from utilizing his assets and properties in the ordinary and normal course of business.