Stay of demand must consider merits and hardship, not rigid 20% pre-deposit

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Stay of demand

In Centre for Policy Research v. DCIT (2025), the Delhi High Court held that a 20% pre-deposit is not mandatory for stay under section 220(6). Assessing Officers must assess prima facie merits, undue hardship, and Revenue interests, rejecting mechanical reliance on CBDT guidelines.

VCH offers specialized transfer pricing services, ensuring compliance, robust documentation, and effective dispute resolution support.

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Substance Check for PE Determination

Stay of demand must consider merits and hardship, not rigid 20% pre-deposit

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sudheer kumar
hyderabad , India