2025 (2) TMI 657

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....e Respondents: Mr. N. C. Ranganayakulu i/b. Ms. Anamika Malhotra. PC.:- (PER M. S. SONAK, J.) 1. Heard learned counsel for the parties. 2. The Petitioner challenges the orders/communications dated 5 July 2024 and 12 December 2024 by which the Assessing Officer (AO) and Principal Commissioner of Income Tax (PCIT) have granted the Petitioner interim reliefs staying recovery of 80% of the de....

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....on the recovery of tax amount. 4. Ms. Malhotra and Mr. Ranganayakulu, learned counsel for the Respondents, defend the impugned orders/communications based on reasoning reflected therein. They point out that the Petitioner was granted sufficient opportunity to prove genuine financial hardship. However, the Petitioner failed to do so. They submitted that the decisions relied upon by the Petitione....

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....arding the unexplained receipts. This is, with respect, neither here nor there. Learned counsel for the Petitioner submitted that financial hardships were only one of the grounds in support of the plea for an unconditional stay. He submitted that the Petitioner relied upon the decisions of this Court, which substantially enhanced the chances of success in the appeal. 8. If the Petitioner is a v....

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....t. Considering the merits of the grounds raised and the decisions relied upon by the Petitioner, at least prima facie, we cannot subscribe to the view that the Petitioner has some cast iron case entitling it to an unconditional stay. 10. In response to the arguments advanced, we could detect several pitfalls. But so as not to prejudice the Petitioner's case on merits in the appeal, we avoid ref....