2026 (7) TMI 968

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....5692, 25696, 26308, 26313 & 26317 of 2026 And WMP Nos. 28044, 28045, 28070, 28071, 28075, 28076, 28079, 28080, 28735, 28736, 28738, 28739, 28747 & 28748 of 2026 - -<br>Income Tax<br>Honourable Mr Justice Senthilkumar Ramamoorthy For the Petitioner : Mr.Srinath Sridevan, Senior Counsel assisted by Mr.Karthik Ranganathan For the Respondents : Dr.B.Ramaswamy, Senior Standing Counsel COMMON O....

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....he Commissioner of Income Tax(A) (CIT (A)) and such appeals are pending. 3. Pending adjudication of the appeals, the petitioner applied under Section 220 (6) of the I-T. Act for stay of recovery of penalty. By orders impugned herein, the petitioner was directed to pay 20% of the amount demanded by way of penalty. 4. Learned Senior Counsel for the petitioner contends that Section 271 C of the....

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....[or ensure payment of,] the whole or any part of the tax as required by or under - (i) sub-section (2) of Section 115-O; or (ii) the proviso to Section 194-B,; (iii) the first proviso to sub-section (1) of Section 194R; or (iv) the proviso to sub-section (1) of Section 194S; or] (v) sub-section (2) of section 194BA] then such person shall be li....

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.... office Memoranda merely laid down guidelines and do not impose any statutory fetter on the exercise of jurisdiction under 220 (6) of the I-T Act. 9. Considering the above facts and circumstances, including revenue interest, at this juncture, subject to remittance of Rs. 4,00,00,000/- (Rupees Four Crore only) in the aggregate towards demands made under all the penalty orders within a period of ....