ORDER ASHOK B. HINCHIGERI - Sri K. M. Shivayogiswamy, the learned Government Pleader is directed to take notice for the respondent. The petitioner has raised the challenge to the notices issued to the Branch Manager, HDFC Bank and to the Army Welfare Housing Organisation, Bangalore (annexures A and B), respectively, under section 45 of the Karnataka Value Added Tax Act, 2003 ("the VAT Act" for short). Sri Chythanya, the learned counsel for the petitioner, submits that section 62(2)(a) of the VAT Act offers the remedy of filing an appeal against the order of reassessment within 30 days. He submits that the respondent is not ready to wait even for the expiry of one month, the prescribed period of limitation for filing the appeal. The respondent has acted in a hurry by resorting to the initiation of the proceedings for the recovery of the amount from the third parties, from whom the money is due to the petitioner. He also expresses the petitioner's readiness to pay 50 per cent. of the amount and file a statutory appeal, but he expresses the difficulty to mobilizing the funds in the wake of the virtual freezing of the accounts, as a result of the issuance of the notices under section 45 of the VAT Act. Sri K. M. Shivayogiswamy, the learned Government Pleader appearing on behalf of the respondent, submits that under section 39(1)(b) of the VAT Act, the assessee is liable to pay the amount demanded towards the reassessment within ten days. The respondent is not required to wait till the expiry of the period prescribed for filing the appeal, so contends Sri Shivayogiswamy. In the course of the rejoinder, Sri Chythanya, the learned counsel for the petitioner, submits that one part of any statute cannot be read to exclude the operation of other part or provision of the statute. He prays for the harmonious blend of the provisions contained in sections 39(1)(b) and 62(2)(a) of the VAT Act. I am not inclined to entertain these petitions on merits, as far as the challenge to the impugned notices issued under section 45 is concerned, because they are only consequential to the passing of the reassessment order. The petitioner has the alternative remedy of filing an appeal to challenge the reassessment order invoking section 62 of the VAT Act. I am not inclined to entertain these petitions on merits, as far as the challenge to the impugned notices issued under section 45 is concerned, because they are only consequential to the passing of the reassessment order. The petitioner has the alternative remedy of filing an appeal to challenge the reassessment order invoking section 62 of the VAT Act. At this juncture, Sri Chythanya, the learned counsel for the petitioner, requests that the petitioner's accounts with the HDFC Bank and the Army Welfare Housing Organisation be de-frozen for the limited period of taking the amount from them for depositing the same with the appellate authority. Sri Shivayogiswamy, on instructions, submits that the HDFC Bank has already sent a sum of Rs. 14,59,000 to the respondent. He brings to my notice that the petitioner's liability under the reassessment order aggregates to about Rs. 81,00,000. He submits that the petitioner is required to make the payment of 50 per cent. of the demanded amount under section 62(4)(c) of the VAT Act, if it wants stay of the reassessment order. Further, the learned Government Pleader fairly submits that the appellate authority would give Weightage to the amount already received and that it would insist for the payment of only about Rs. 25,91,000 (Rs. 40,50,000 (pre-requirement for seeking the stay) minus Rs. 14,59,000 (amount received from HDFC Bank)). He further submits that if the HDFC Bank or the Army Welfare Housing Organisation sends about Rs. 25,91,000, then it would be taken that the petitioner has complied with the requirement of depositing 50 per cent. of the demanded amount; it thus qualifies to have its application for stay considered on merits before the appellate authority. In the light of these submissions, this court forms the considered view that the ends of justice would be met by directing the appellate authority to dispose of the petitioner's I.A. for stay in the anticipated appeal on the same day on which they are filed, provided, the petitioner deposits the remaining Rs. 25,91,000 (rupees twenty five lakhs ninety one thousand only) or the said amount comes from the Army Welfare Housing Organisation and/or the HDFC Banks. Needless to observe that, if the petitioner does not file the appeal and I.A. for stay and/or the sum of Rs. 25,91,000 (rupees twenty five lakhs ninety one thousand only) or the said amount comes from the Army Welfare Housing Organisation and/or the HDFC Banks. Needless to observe that, if the petitioner does not file the appeal and I.A. for stay and/or the sum of Rs. 25,91,000 does not come from the petitioner or the said third parties or if no stay is granted, it is always open to the respondent to act in accordance with law to recover the amount demanded on account of the passing of the reassessment order. These petitions are disposed of accordingly. No order as to costs.