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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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Section 226 & 251 of the Income-Tax Act, 1961—Appeal—ARANATTUKARA ORIENTAL SERVICE CO-OPERATIVE BANK LTD. vs. CIT.[2020] 25 ITCD Online 102 (KER)