High Court directs stay application filing before CIT (Appeals) for bank account attachment, speedy review.

The High Court addressed the rejection of the petitioner's application under Section 220(6) by the Assessing Officer, leading to bank account attachment. The court allowed the petitioner to file a stay application before the CIT (Appeals) and directed prompt consideration within two weeks. If relief is granted, any excess recovered amount must be returned. The CIT (Appeals) must issue a reasoned order on the stay application. The petition was disposed of with instructions for procedural fairness and protection of rights.

---

---

Issues:
1. Rejection of application under Section 220(6) by the Assessing Officer and consequent attachment of bank accounts.
2. Grievance of the petitioner regarding the rejection and attachment.
3. Permission granted to file a stay application before the CIT (Appeals).
4. Directions given to CIT (Appeals) to consider the stay application and pass an order within two weeks.
5. Restitution of any excess amount recovered if relief is granted by CIT (Appeals).
6. Requirement for CIT (Appeals) to pass a reasoned order on the stay application.

Analysis:
1. The High Court addressed the issue of the rejection of the petitioner's application under Section 220(6) by the Assessing Officer, which led to the attachment of the petitioner's bank accounts. The court noted that the petitioner's appeal was pending before the CIT (Appeals), indicating a legal recourse already in progress.

2. The court acknowledged the petitioner's grievance concerning the rejection and attachment, prompting the court to permit the petitioner to file a stay application before the CIT (Appeals) immediately. This step aimed to provide the petitioner with an opportunity to seek relief through the appropriate legal channel.

3. Upon granting permission to file the stay application, the High Court directed the CIT (Appeals) to consider the application promptly and issue an order within two weeks. This directive emphasized the importance of timely resolution and indicated the court's expectation for expeditious decision-making by the CIT (Appeals).

4. In the event that the CIT (Appeals) granted relief to the petitioner after due consideration, the High Court ordered the restitution of any excess amount that may have been recovered beyond the granted relief. This instruction ensured fairness and protection of the petitioner's financial interests in case of a favorable outcome.

5. Furthermore, the High Court emphasized the necessity for the CIT (Appeals) to pass a reasoned order on the stay application filed by the petitioner. This requirement aimed to promote transparency, accountability, and legal soundness in the decision-making process, ensuring that all aspects of the case were duly considered and documented.

6. Ultimately, the High Court disposed of the petition based on the terms outlined in the judgment, providing clarity on the actions to be taken by the petitioner, the CIT (Appeals), and the respondent. The court's decision sought to uphold procedural fairness, legal compliance, and the protection of the petitioner's rights within the framework of the law.

---