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

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.... the income determined on assessment was substantially higher than the returned income, say, twice the latter amount or more, the collection of the tax in dispute should be held in abeyance till the decision on the appeal by the AAC provided there was no lapse on the part of the assessee. It was also stated therein that the powers of stay of recovery in such cases upto the stage of first appeal mi....

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....be stayed in cases where substantial points of dispute are involved. The effect of these two Instructions is that collection of tax under dispute should be held in abeyance till the decision of appeal by the AAC. (i) In cases where the income determined on assessment is substantially higher than the returned income, say, twice the returned income or more, provided there were no lapses on the part....

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.... In order to prevent any substantial rise in arrears as a result of granting stay under section 220(6), the Commissioners should ensure strict adherence to the Instructions contained in para 2 of the Board Instructions No.317 (F.No.279/142/71-ITJ) dated 4th August, 12971, regarding early disposal of high demand appeals by AACs. They should obtain list of cases where such demands are kept in abeyan....