Conditional stay on tax demand upheld where assessments relied on digital evidence and incriminating material, not retracted statements.

A conditional stay order requiring payment of 20% of the tax demand in instalments was upheld because the assessment orders reflected consideration of survey statements together with other incriminating material, including excel sheets and digital data recovered from computers and laptops. The contention that the assessments rested only on later retracted statements was rejected. As the challenge did not show any basis to interfere with the stay conditions, the writ petition was dismissed.

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Issues: Whether the conditional stay order directing payment of 20% of the tax demand, with instalments, warranted interference on the ground that the assessment orders were passed without considering the merits of the case.

Analysis: The assessment orders showed that the authorities had considered not only the statements recorded during survey but also other incriminating material, including excel sheets and digital data recovered from computers and laptops, before making the additions. The contention that the orders were based merely on later retracted statements was not accepted. In those circumstances, no case was made out to interfere with the conditional stay order.

Conclusion: The challenge to the conditional stay order failed and the writ petition was dismissed.

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