Revenue's Failure to Explain Higher Tax Collection Justified: Petitioner Denied Opportunity to Contest Under Usual 15% Stay Practice.

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....Pre-deposit - When the petitioner had no idea on what grounds the authorities primafacie thought that the standard formula of granting stay on depositing 15% of the disputed tax demand would not be appropriate, it was incumbent upon the Revenue to put such reasons to the petitioner enabling the petitioner to meet with such grounds and oppose higher collection by raising suitable defense - HC....