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of Stay of demand - waiver of 20% of the pre-deposit - We fail to understand what is so magical in the figure of 20%. To balance the equities, the authority may even consider directing the assessee to make a deposit of 5% or 10% of the assessed amount as the circumstances may demand as a pre-deposit. The “High Pitched Assessment” means where the income determined and assessment was substantially higher than the returned income. - The application under Section 220(6) of the Act cannot normally be rejected merely describing it to be against the interest of Revenue if recovery is not made, if tax demanded is twice or more of the declared tax liability. - HC
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