2022 (12) TMI 1432

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....s involved in these appeals are common and germane, both the appeals are disposed of by this common judgment and order. For the sake of convenience, we take up MAT 244 of 2020 for discussion. Re: I.A. No.CAN 1 of 2020 (Old CAN 2510 of 2020) 2. This is an application to condone the delay of 469 days in filing the instant appeal. 3. We have heard Mrs. Manju Agarwal, learned counsel appearing for the appellant and Mr. Smarajit Roychowdhury, learned counsel appearing for the respondents. 4. We are satisfied with the reasons assigned in the affidavit filed in support of the application. Accordingly, the delay in filing the instant appeal is condoned. 5. The applications for condonation of delay being I.A. No.CAN 1 of 2020 (Old CAN 2510 of 2....

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....ed assessments are appealed against and an order of stay is sought for either before the assessing officer by filing an application under Section 220(6) of the Income Tax Act, orders are passed by the assessing officer either keeping the notice of recovery in abeyance and not treating the assessee as an assessee in default till the appeal is disposed of. 10. There are yet another set of cases where the assessing officer for reasons to be recorded imposes certain conditions as a condition for grant of stay. The appellant's case falls under the second category where the assessing officer has directed 20% of the demand to be paid by the assessee for being entitled to grant of stay. 11. It is an undisputed fact that as against the impugned as....