$~62 * IN THE HIGH COURT OF DELHI AT NEW DELHI Date of decision: 9^th March, 2026 + W.P.(C) 2932/2026 & CM APPL. 14140/2026 ORAVEL STAYS LIMITED .....Petitioner Through: Mr. Ajay Vohra, Sr. Advocate with Mr. Manuj Sabharwal, Advocate.

versus COMMISSIONER OF INCOME-TAX (TDS)-2, DELHI & ORS.

.....Respondents Through: Mr. Puneet Rai, SSC.

CORAM:

HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE MR. JUSTICE VINOD KUMAR

J U D G M E N T

DINESH MEHTA, J. (ORAL)

1. By way of present writ petition, the petitioner-assessee has challenged order of the Commissioner of Income Tax (TDS-2), Delhi (hereinafter referred to as ‘Appellate Authority’) passed on 09.02.2026, vide which the petitioner’s stay application has been disposed of in the manner that subject to payment of 20% of the total demand, remaining demand shall remain stayed.

2. Mr. Ajay Vohra, learned Senior Counsel assisted by Mr. Manuj Sabharwal appearing for the petitioner firstly invited Court’s attention towards the orders dated 31.03.2025 passed in petitioner’s own case (Annexure P-12 & P-13) for assessment years 2018-19 and 2019-2020, respectively and argued that the predecessor of the Assessing Officer himself had held the petitioner not to be