SABYASACHI MUKHARJI, J.

( 1 ) IN respect of the assessment year 1962-63 the petitioner-company submitted a return showing certain loans alleged to have been obtained from different persons. The Income-tax Officer assessed the income including these alleged loans as income from sources undisclosed as he disbelieved the version of the petitioner that these were loans. The petitioner preferred an appeal before the Appellate Assistant Commissioner. In the meantime it appears that the Income-tax Officer had forwarded a certificate to the Tax Recovery Officer and the Tax Recovery Officer had issued a notice under Rule 2 of Schedule II of the Income-tax Act, 1961. The petitioner had also prayed to the Income-tax Officer for grant of a stay of realisation until the disposal of the appeal before the Appellate Assistant Commissioner. On June 29, 1968, the Income-tax Officer bad granted a stay of the certificate up to 30th June, 1968. He informed that to the certificate officer and also had informed that fact to the petitioner. The appeal before the Appellate Assistant Commissioner has not yet been disposed of. The petitioner further applied to the Income-tax Officer for extension of the sta

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