THE HON’BLE THE CHIEF JUSTICE SRI APARESH KUMAR SINGH AND THE HON’BLE SRI JUSTICE G.M.MOHIUDDIN

ORDER:

Heard Ms. Akruti Agarwal, learned counsel appearing for petitioner; Mr. Vijhay K Punna, learned Senior Standing Counsel for Income Tax appearing for respondent Nos.1 to 3 and Sri B. Mukherjee, learned counsel appearing for Sri N. Bhujanga Rao, learned Deputy Solicitor General of India for respondent No.4.

2. Earlier, the order dated 23.08.2025 passed by respondent No.1 - Commissioner of Income-tax (Exemption), Hyderabad (for short ‘CIT (Exemption)’), granting a conditional stay of the demand on making partial payment of Rs.8.00 crore on or before 01.09.2025 in relation to the proceedings for recovery of taxes for the Assessment Year 2023-24 during pendency of the appeal was set aside by this Court vide order dated 23.09.2025 in Writ Petition No.28734 of 2025 and remanded to CIT (Exemption) to pass a fresh speaking order after considering the grounds raised by the assessee in its stay petition. Detailed speaking order dated 13.10.2025 passed thereafter by CIT (Exemption) whereby the petitioner was directed to deposit Rs.8.00 crore, which is less than the CBDT guidelines of 20%, on o