JUDGMENT :

1. This writ petition under Article 226 of the Constitution of India is filed by the petitioner challenging the order dated 03.03.2023 passed by respondent No.1-PCIT, Jaipur, whereby application filed by the petitioner seeking stay of recovery of demand pertaining to assessment years 2014-15, 2016-17 and 2020-21 has been disposed of in the following manner :

"The petition is disposed off subject to following stipulation(s):-

1. The Outstanding aggregate demand of Rs.25,12,77,982/- to be stayed till disposal of 1st appeal only upon payment of 20% of demand as per above schedule.

2. The applicant is directed to make payment as per the above schedule.

3. The assessee shall co-operate in early disposal of the appeal pending before the Ld. CIT(A).

4. Revenue retains the right to reconsider/review the payment plans/ stipulations as well as the stay order anytime in case of any exigency or administrative requirement or to safeguard the interests of revenue.

5. This order does not confer any legal right to the assessee. No finding or adjudication on assessee's pending matters can be inferred from this order. The assessee shall not act in any manner that may cause prejudice to interests