Assessing Officer passed assessment order holding that seller from whom assessee made purchases had not filed its return of income and raised demand upon assessee. The assessee filed an appeal before the CIT(A).  The assessee received a demand notice to pay 25 per cent of assessed tax. On writ the assessee contended he is  not liable to submit any evidence to prove seller’s return and other particulars of seller, it was not liable to pay 25 per cent demand more so when statutory appeal was pending before Commissioner (Appeals). The Court held that  the assessee is not liable to submit seller’s stock register. The Appellate Authority shall consider the issue on its own merits uninfluenced by the observation of this order. Demand notice was stayed.  (AY. 2021-22)