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Issues involved:
The judgment deals with a writ petition challenging an order passed by the Income-tax Appellate Tribunal regarding a stay application for assessment years 1999-2000 to 2005-06, specifically focusing on the amount of deposit directed by the Tribunal. Details of the judgment: 1. The writ petition challenged the order of the Income-tax Appellate Tribunal dated 25-1-2010, which directed the petitioner to deposit 20 per cent of the outstanding demand in two equal instalments falling due on 15-2-2010 and 15-3-2010. The petitioner contended that the original order required payment of Rs. 5 crores in two equal instalments, leading to confusion about the correct amount to be deposited. 2. The petitioner filed a miscellaneous application under section 254(2) of the Income-tax Act, 1961, seeking rectification of the alleged mistake in the Tribunal's order dated 25-1-2010. The petitioner claimed that the original order pronounced in open court on 22-1-2010 mandated payment of Rs. 2.5 crores by 15-2-2010 and another Rs. 2.5 crores by 15-3-2010, with the balance tax demand stayed until 26-3-2010. 3. The Revenue's counsel argued that the order pronounced in open court was accurately reflected in the written order. The Revenue clarified that the Tribunal had indeed directed the deposit of 20 per cent of the demand, contrary to the petitioner's interpretation of the order requiring payment of Rs. 5 crores in two instalments. 4. The High Court acknowledged the dispute over the correct interpretation of the Tribunal's order and directed the Tribunal to expedite the hearing of the petitioner's rectification application, scheduled for 18-2-2010. The Court emphasized the need for prompt resolution to avoid further complications arising from differing interpretations of the original order. 5. In light of the above, the High Court disposed of the writ petition with the directive for the Tribunal to address the rectification application promptly on 18-2-2010, aiming to clarify the confusion surrounding the amount of deposit required by the Tribunal's order.
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