TMI Blog1973 (3) TMI 121X X X X Extracts X X X X X X X X Extracts X X X X ..... are informed that it is not proposed to stay the collection of further amount of tax of Rs. 1,40,041.21 due from them under section 39-A(2) of the Act." Section 39-A(2) says that, pending the exercise of the powers of appeal, revision or review, the appropriate appellate authority, or revising or reviewing authority may, on application made by the assessing authority or the assessee, stay the re ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is case required the assessees to furnish security in order that he might consider the grant of stay. This requisition was not complied with. If that be so, we could see nothing wrong in the impugned order. In fact, the assessees before us do not dispute the fact that the Appellate Assistant Commissioner has asked for security. But what is pointed out for the assessees is that the security was ask ..... X X X X Extracts X X X X X X X X Extracts X X X X
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