A.O.'s discretion u/s 220(6).

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....the case treat the assessee as not being in default in respect of the amount in dispute in the appeal even though the time for payment has expired as long as such appeal remains undisposed of. 2. The Board had issued detailed guidelines vide Instruction No.1362 dated 15-10-80 regarding the factors which should be taken into account by the Assessing officer while exercising his discretion u/s.220(....