Petitioner ordered to pay monthly sum; appeal after full payment; separate from pending appeal rights.

The court ordered the petitioner to pay a monthly sum until the total amount is settled, failing which would result in the revival of the Assessment Order without protection. The appeal would only be heard after full payment as directed, with a specific payment schedule set. The payments required were separate from the rights in the pending appeal. The Writ Petition was disposed of with these directions, and no costs were awarded, leading to the closure of connected Writ Miscellaneous Petitions.

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Issues:
1. Stay of recovery proceedings pending appeal.
2. Amount to be deposited for appeal to be heard.
3. Attachment of bank accounts due to non-payment.
4. Payment schedule directed by the court.
5. Impact on appeal proceedings.

Analysis:
1. The petitioner filed a Writ Petition seeking a stay on the recovery proceedings after receiving the Assessment Order for the Assessment Year 2018-2019. The petitioner also appealed to the Commissioner of Income Tax (Appeals) and filed an application under Section 220(6) of the Income Tax Act, 1961 to stay the recovery proceedings.

2. The respondent, referring to circulars issued by the Central Board of Direct Taxes, ordered the petitioner to deposit 20% of the tax due for the appeal to be heard, with the condition that stay would be granted pending the appeal's disposal. The petitioner requested to deposit the amount in monthly installments, but as the full amount was not paid, the respondent attached the petitioner's bank accounts.

3. The court directed the petitioner to pay a monthly sum of &8377; 30,00,000 until the total amount of &8377; 2,98,81,885 is paid. Failure to make payments by the specified date would result in the protection under the order being revoked, allowing the respondent to attach the bank accounts. The Assessment Order would then stand revived without any reference.

4. The court specified that the appeal before the Commissioner of Income Tax (Appeals) would only be heard after the petitioner pays the entire amount as directed. The payment schedule was set with the first installment due by a specific date.

5. The court emphasized that the payments required from the petitioner were without prejudice to their rights in the appeal pending before the Commissioner of Income Tax (Appeals). The Writ Petition was disposed of with these directions, and no costs were awarded. Connected Writ Miscellaneous Petitions were also closed as a consequence of this judgment.

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