Interim stay of disputed tax in revision remains exceptional, while instalment relief survives despite the no-stay provision.

Section 22(6) requires tax to be paid according to the assessment, but its first proviso preserves the High Court's discretion to permit instalments and issue other payment directions. Section 22(6-A) bars a stay of payment pending revision, yet does not extinguish that discretionary power. Read harmoniously, the High Court may grant limited interim relief in special circumstances, including a stay in exceptional cases to avoid grave miscarriage of justice, but the power must be exercised sparingly. On the stated facts, concurrent adverse findings, no grave hardship, and no shown miscarriage of justice meant a complete stay was not justified; instalment relief alone was appropriate.

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Issues: Whether, in a revision under section 22(1) of the Andhra Pradesh General Sales Tax Act, 1957, the High Court can direct stay of recovery of disputed tax or permit payment in instalments despite section 22(6-A), and whether such relief should be granted on the facts of the case.

Analysis: Section 22(6) mandates payment of tax according to the assessment, but its first proviso confers discretion on the High Court to permit payment in instalments and to give such other directions regarding payment of tax as it thinks fit. Section 22(6-A) declares that payment of tax and penalty in accordance with the appellate order shall not be stayed pending disposal of the revision, but it does not take away or control the discretionary power under the first proviso to section 22(6). On a harmonious construction of the provisions, the High Court may, in appropriate cases and in special circumstances, even direct that tax not be recovered pending revision, but such power must be exercised sparingly to prevent grave miscarriage of justice. On the facts, the concurrent findings of the authorities against the petitioner, the absence of any showing of miscarriage of justice, and the absence of grave hardship made a complete stay unwarranted.

Conclusion: The High Court had power to grant limited interim relief in appropriate cases, but the petitioner was not entitled to stay of recovery in toto; only instalment relief was justified.

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