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of HC accepted petitioner's alternative proposal to pay additional 5% of outstanding tax demand for AY 2011-12, bringing total payment to 20% of assessed amount. This compliance with CBDT instructions dated 31.07.2017 results in stay of balance demand. Court deemed adjustment of AY 2024-25 refund against AY 2011-12 demand permissible, subject to increased payment. Ruling aligns with established tax administration guidelines on partial payment requirements for demand stays. Court found proposal equitable, balancing revenue interests with taxpayer's financial position.
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