Court held that rejection of stay application for stay on demand and directed assessee to pay 20 per cent of amount demanded by relying wholly on CBDT Instruction No. 1914 dated 2-2-1993, impugned order being passed without application of mind was to be set aside. Directed to pay only 10 per cent of demand. (AY. 2012-13)
Zinzuwadia and Sons v. DCIT (2019)419 ITR 169/ 265 Taxman 261/183 DTR 65/311 CTR 297 (Guj.)(HC)
S. 220 : Collection and recovery-Assessee deemed in default–Stay–Rejection of stay application and directing to pay 20 percent of demand, without application of mind is held to be bad in law. (Art. 226]