Shanti Prime Publication Pvt. Ltd.
Sec. 220 of Income Tax Act, 1961 — Recovery of Tax — The parameters to be taken into account in considering the grant of stay of disputed demand are well settled. The existence of a prima facie case, financial stringency and the balance of convenience. 'Financial stringency' would include within its ambit the question of 'irreparable in jury' and 'undue hardship' as well. It is only upon an application of the three factors as aforesaid that the assessing officer can exercise discretion for the grant or rejection, wholly or in part, of a request for stay of disputed demand— Jayanthi Seeman vs. Pr. CIT [2020] 421 ITR 320 (MAD)