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TMI Blog2019 (8) TMI 621X X X X Extracts X X X X X X X X Extracts X X X X ..... As far as the issue regarding the prima facie case in favour of the Petitioners is concerned, the Court notes that by the impugned order, the PCIT has not mechanically required the Petitioners to pay 20% of the total demand, but has used the discretion, and passed a reasoned order, determining the amount payable at around 14% of the total demand. Having considered the submissions in light of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 19 CM 34378/2019 (exemption) in W.P.(C) 8299/2019 CM 34381/2019 (exemption) in W.P.(C) 8300/2019 1. Allowed, subject to all just exceptions. W.P.(C) 8293/2019 CM 34354/2019 (stay) W.P.(C) 8294/2019 CM 34356/2019 (stay) W.P.(C) 8299/2019 CM 34377/2019 (stay) W.P.(C) 8300/2019 CM 34380/2019 (stay) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d in a tabular form the summary of the issues involved and the demands raised against each of the Petitioners in terms of the assessment orders. The Court has also examined Instruction No. 1914 dated 2nd February, 1993 issued by the Central Board of Direct Taxes ( CBDT ) to guide the CIT seized of an application under Section 220 (6) of the Act. 4. The Court finds that in terms of the tot ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ings, particularly since they are pending consideration in the Petitioners appeals before the CIT (A). As far as the issue regarding the prima facie case in favour of the Petitioners is concerned, the Court notes that by the impugned order, the PCIT has not mechanically required the Petitioners to pay 20% of the total demand, but has used the discretion, and passed a reasoned order, determining t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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