CIT APPEALS PRE DEPOSIT

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my case was selected for 144 Best judgement assessment. I went to cut appeals. they were asking me to pre deposit 20%. what happens if I loose or if I win the case. is the pre deposit amount will be refunded because in sec 144 it was mentioned that a o can assess tax payable only. kindly guide me.
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Pre deposit 20 percent required for stay of demand if appeal decision in favour than pre deposit amount refunded


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