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It is made clear that observations made herein are only in the context of the order of stay passed under s. 220(6) of the Act. Our observations are onlyprima facieview for the limited purpose of disposal of the stay application. It would not have impact/influence on the CIT(A) while considering the petitioner’s appeal on merits for the order dt. 30th May, 2019 of the AO. The CIT(A) will dispose of the appeal on its own merits without in any manner being influenced by any observation in this order.

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Section 220(6) of the Income Tax Act, 1961 — Recovery — Stay — In view of conflicting decisions of Tribunal, complete stay is to be granted on demand pertaining to that issue. further, decision of the jurisdictional High Court was binding on CIT(A) and he was not justified in following the decision of CIT(A) for the earlier assessment year. demand pertaining to three issues thus stayed — General Insurance Corporation of India vs. Assistant Commissioner of income tax [2019] 311 CTR (Bombay) 851

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