V.K. Singhal, J.—The validity of notices issued under Section 226(3) of the Income Tax Act, 1961, has been assailed in all these petitions and therefore they are disposed of by this common order.

2. The controversy is regarding attachment of fixed deposit receipts which have been attached on account of non-payment of Income Tax dues by the assessees. Garnishee proceedings have accordingly been taken.

3. The only point to be determined is as to whether the petitioner bank is under obligation to make the payment of fixed deposit of the assessees in default before its maturity.

4. According to learned counsel for the petitioner in accordance with the contract entered into, fixed deposit is payable at a later date and therefore it has not become due/The relevant provisions of Section 226(3)(i) and (iv) are as under :

"226. (3)(i) The Assessing Officer or Tax Recovery Officer may, at any time or from time to time, by notice in writing require any person from whom money is due or may become due to the assessee or any person who holds or may subsequently hold money for or on account of the assessee, to pay to the Assessing Officer or Tax Recovery Officer either forthwith upon the mone