Stay of demand more than 2 times returned income

This query is : Resolved

Kunjan (Querist)
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07 June 2025 if assessed income is more than 2 times the returned income , demand cannot be pressed till cit(a) decides.

is it correct?
my view --> yes, in view of CBDT instruction No. 96 dated 21/8/1969 and Instruction No. 1914 of 1993 dated 2/12/1993, where the income determined in substantially higher than the returned income, that is twice the latter amount or more, then the collection of Tax in dispute should be held in abeyance till the decision on appeal is taken

i feel Yes, in view of CBDT instruction No. 96 dated 21/8/1969 and Instruction No. 1914 of 1993 dated 2/12/1993, where the income determined in substantially higher than the returned income, that is twice the latter amount or more, then the collection of Tax in dispute should be held in abeyance till the decision on appeal is taken

stakes are high, hence asking opinion.