Reasoned discretion in tax-demand stays requires merits-based consideration, preventing mechanical rejection for pending appeals or circular-payment defaults.

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....Stay applications against recovery of disputed income-tax demand require a reasoned exercise of discretion based on factors relevant to granting or refusing interim protection. Rejection solely because an appeal is pending, no separate stay order exists, or the prescribed demand percentage has not been paid under an applicable circular is mechanical and insufficient. The decision-maker must record consideration of the merits relevant to the stay request. The rejection was set aside and remitted to the competent authority for fresh reasoned consideration within one month, without deciding the underlying tax dispute.....