When the appeal is pending before the CIT(A), the Department had insisted  to deposit 10 per cent. of the demand when the assessee had a strong prima facie case. On writ the Court held that the deposit would itself occasion undue hardship to the assessee which was a trust created for the purpose of benefiting the employees. They would not be liable to pay such a high demand if their assessment was considered in their capacity as a trust as against the status of a firm. Court directed the Department  to consider the assessee’s application under their status as a trust and try to dispose of the matter preferably within a period of four months from the date of this order. No coercive steps shall be taken against the assessee for the recovery of the demand in pursuance of the impugned notice dated March 30, 2022.(AY.2014-15, 2017-18)