irst Petitioner does have serious issues to be urged before the Commissioner of Income Tax (Appeals) in appeal. This is a case where the Assessing Officer while exercising the jurisdiction under Section 220(6) and the Director of Income Tax ought to have granted a complete stay of demand. The Assessee has highlighted the nature of its activities in several applications filed in support of the plea for stay and also explained its financial position. None of this has been taken into account while disposing of the application for stay.
