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<h1>Stay denied; deposit 20% by 03.10.2025; bank accounts to be released; challenge to CIT within one week for remaining 80%</h1> HC rejected stay application and directed petitioner to deposit 20% of the demand with the Government by 03.10.2025, forwarding the Challan to the AO ... Stay application rejected - CIT has directed the bank to attach/freeze the thirteen accounts. HELD THAT:- SSC for the respondent appears on advance notice and has taken instructions from the officer concerned. According to him, that on the petitioner depositing twenty percent of the demand, the thirteen accounts which have been attached/frozen by the respondent authority shall be de-attached/released and the communication in this regard shall be sent to the Bank. If that be so, the twenty percent of the demand shall be deposited by the petitioner with the Government on or before 03.10.2025 and a communication/copy of Challan shall be forwarded to the AO forthwith. In order to enable the petitioner deposit the twenty percent of the demand, which according to counsel for the petitioner is Rs. 1.65 crores (approximately), the bank accounts which have been attached shall be released/ de-attached immediately on receipt of this order. Liberty is with the appellant to approach the CIT by way of an application challenging the order of the AO within a period of one week that is on or before 03.10.2025 which shall be considered by the CIT on the aspect of balance eighty percent of the amount. Challenge to AO's order rejecting stay and communication under Section 226(3) of the Income-tax Act directing HDFC Bank to attach thirteen bank accounts for recovery of demand. AO rejected the petitioner's stay application on 23.09.2025 and issued attachment notice dated 24.09.2025. Petitioner asserted prejudice because salaries and statutory dues fall due. Respondent offered that on deposit of 'twenty percent of the demand' the attached accounts would be de-attached/released and communication sent to the Bank. Direction: petitioner to deposit twenty percent of the demand (approx. Rs. 1.65 crores) with the Government on or before 03.10.2025 and forward the Challan to the AO; upon receipt the bank accounts shall be released immediately. Liberty granted to petitionerto approach the CIT by way of application challenging the AO's order on or before 03.10.2025; the CIT to consider the balance eighty percent. All rights and contentions are kept open. Failure to deposit within the time will attract a 'serious view.'