Assessee is  a co-operative society registered under Kerala Co-operative Societies Act and classified as a Primary Agricultural Credit Society. It filed return claiming deduction under S. 80P of the Act. The AO  disallowed deduction under S.  80(P)(2)(a)(i) and further made additions to income declared by assessee under S. 68 of the Act.  In a stay application preferred by assessee before first appellate authority, a conditional stay was granted subject to assessee paying 20 per cent of tax amount attributable to additions to income made under S. 68 of the Act. Against said order, assessee approached PCIT by invoking provisions of S. 220(6) of the Act. PCIT  directed the assessee to pay 50 per cent of demand on account of deduction under S.  80P in addition to demand on addition made under S. 68 of the Act. On writ the court held that  in view of decision in Mavilayi Service Co-operative Bank Ltd. v. CIT [2019] (2) KHC 287 impugned petition was to be disposed of with a direction to pay only one per cent of tax demanded on addition made in assessment order under S.68 of the Act.