Exercise of discretion under section 220(6) of the Income-tax Act, 1961, to treat the assessee as not being in default in respect of the amounts disputed in first appeal pending before the Deputy Commissioner (Appeals)/Commissioner (Appeals)

Discretion under section 220(6) permits AOs to consider all relevant factors before treating an assessee not in default.

Assessing Officer discretion is to be exercised by considering all relevant factors bearing on a tax demand and by communicating the decision to the assessee in the form of a speaking order; this applies to deciding whether to treat an assessee as not in default for amounts disputed in first appeal.