Assessee, an educational and charitable society registered under section 12A, faced scrutiny leading to a tax liability of Rs. 2.50 crores on its gross receipts of Rs. 5.25 crores . Assessee submitted a rectification application under section 154, which remained undecided for over 2½ years  Assessee also challenged demand before appellate authority and sought a stay under section 220(6), which was partially granted, directing payment of Rs. 35 lakhs by a certain date . On writ  the Court held that the  assessee is a charitable establishment and had been availing exemption from payment of income-tax all along, prior to issuance of demand notice and even in subsequent years as well. Therefore, considering status of assessee, which was a charitable establishment with a charitable object and purpose, assessing authority should have allowed application under section 220(6) . Stay is  granted on entire demand till disposal of appeal .(AY. 2018 -19)