Collection of tax in dispute be held in abeyance till the decision on the appeal by the AAC.

Stay of tax collection pending appeal where assessment greatly exceeds return and recovery would cause hardship.

Collection of tax under dispute should be held in abeyance pending first appeal where assessed income substantially exceeds returned income or where substantial points of dispute make recovery likely to cause hardship. The ITO may pass orders under section 220(6) in ordinary cases, but where additions follow directions of the Inspecting Assistant Commissioner the ITO must obtain prior administrative approval of that officer. Commissioners must ensure prompt disposal of such appeals to avoid arrears; the ITO's discretion in other suitable cases remains unaffected.