https://www.taxtmi.com/caselaws?id=801413 CBDT instructions on stay and recovery of disputed demands before the first appellate authority ordinarily limit recovery to 20% of the demand, with the balance stayed pending appeal. This limitation applies equally to penalty demands and assessment demands because the instructions draw no distinction between them. Refunds relating to other assessment years cannot be adjusted in full against a disputed penalty demand while first appeals and stay applications remain pending. Any adjustment exceeding the prescribed recovery extent must be reversed and refunded with applicable interest, while the balance demand remains stayed until disposal of the appeal. en-us Wed, 14 Oct 2026 00:00:00 +0530 Wed, 21 Oct 2026 08:37:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=801413 CBDT instructions on stay and recovery of disputed demands before the first appellate authority ordinarily limit recovery to 20% of the demand, with the balance stayed pending appeal. This limitation applies equally to penalty demands and assessment demands because the instructions draw no distinction between them. Refunds relating to other assessment years cannot be adjusted in full against a disputed penalty demand while first appeals and stay applications remain pending. Any adjustment exceeding the prescribed recovery extent must be reversed and refunded with applicable interest, while the balance demand remains stayed until disposal of the appeal. Case-Laws Income Tax Wed, 14 Oct 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=801413