ORDER

PER RAMIT KOCHAR, AM:

Thesetwo stay applications in SA nos. 338 & 339/Del/2025, arising out of ITA nos. 2442 & 2443/Del/2022 pertaining to assessment year(s): 2017-18 & 2018-19 respectively, havebeen filed by the assessee, seeking extension of stay on recovery of outstanding demand(s) for these two assessment years viz. ay:2017-18(Rs.3,02,97,95,228/-) and ay:2018-19(Rs.1,55,17,03,177/-), aggregating to Rs.458.15 crores.

2. We have heard learned counsel for the assessee as well ld. Sr. DR. It was submitted by the learned Counsel appearing for the assessee that earlier the Tribunal had originally granted stay on recovery of outstanding demand vide common order dated 23.12.2022 in SA no. 346 & 347/Del/2022 for assessment years 2017-18 and 2018-19, which stay on recovery of outstanding demand was extended from time to time, the last extension of stay was granted by ITAT vide common orders dated 03.01.2025 in SA Nos. 537 & 538/Del/2024 for assessment years 2017-18 and 2018-19(placed on record in file). It was submitted by learned Counsel for the assesseethat the Tribunal stipulated that 20% of the outstanding demand be deposited by the assessee as a pre- conditions of stay on recov