Commissioner (Appeals) Must Independently Assess Stay of Demand Requests, Not Bound by CBDT Circulars, Acting Quasi-Judicially.

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....Stay of demand - 1st respondent as the appellate authority exercises quasi-judicial powers. Power to consider prayer for stay is incidental and ancillary to the power to hear appeals. As a quasi-judicial authority, Commissioner (Appeals) is not bound by the administrative circulars issued by CBDT. He has to apply his own independent mind in the facts and circumstances of each case. - HC....