Section 220(6) stay relief requires merits-based consideration and refund of recovery above the 20% threshold.

Pending a statutory appeal, the tax authorities were required to examine the taxpayer's request under section 220(6) of the Income-tax Act on its merits and not treat the representation as already concluded by the assessment recovery. The court directed reconsideration within six weeks and required refund of any amount recovered beyond the 20% threshold, reinforcing that recovery should not exceed the prescribed limit without proper consideration of the stay request.

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Issues: Whether, pending the statutory appeal against the assessment order, the respondents were required to consider the petitioner's representation under section 220(6) of the Income-tax Act, 1961 and refund the amount recovered in excess of the 20% threshold.

Outcome: The respondents were directed to consider the representation on merits within six weeks and to refund any amount recovered in excess of 20%.

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