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There will be a direction to the 1st respondent to decide the appeal on merits within a period of six months, without asking for 20% of the demanded amount, after affording an opportunity of hearing to the petitioner and the revenue and pass a reasonable and speaking order.

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Sec. 226 & 251 of the Income-Tax Act, 1961 - Appeal -The AO or the appellate authority while exercising the power of appeal or stay of the assessment proceedings under section 226 of the Income-tax Act 1961 are enjoined obligation to give regard and respect to the directions of the Hon'ble High Court. In other words, it would not be necessary that the payment of 20% can be dispensed with only if there is an order of the high court. The judgment of the Full Bench followed by the Division Bench has an ensuring effect on all the authorities. - ARANATTUKARA ORIENTAL SERVICE CO-OPERATIVE BANK LTD. V/s CIT - [2020] 273 TAXMAN 165 (KER)