1 CGHC010248962025 2026:CGHC:38894 NAFR HIGH COURT of CHHATTISGARH AT BILASPUR WPT No. 93 of 2025 Shri Mahavir Iron And Steel Private Limited Having Its office At Mahavir Saw Mill, New Timber Market, Fafadih Raipur, C.G.- 492001 Through Its Director Devram Patel S/o Mavji Patel Aged About 44 Years R/o Ambaji Niwas, Indira Timber Market, Bhanpuri District Raipur C.G.. ... Petitioner versus 1 - Deputy Commissioner of Income Tax Central Circle- 1/(Central-1), Raipur, office of The Deputy Commissioner of Income Tax, Central Circle-1/(Central)- 1, Aayakar Bhawan, Civil Lines, Raipur, (C.G.)- 492001 2 - National Faceless Appeal Centre, Delhi Through Principal Chief Commissioner of Income Tax (Na F A C), Delhi, North Block, New Delhi- 110001 3 - Chief Commissioner of Income Tax, Raipur, office of Chief Commissioner of Income Tax Raipur, Central Revenue Building Civil Lines, Raipur, (C.G.)- 492001 4 - The Union of India Through Its Secretary Department of Revenue, Ministry of Finance, Noth Block, New Delhi- 110001 ... Respondent(s) For Petitioner : None in two rounds. For UOI : Mr. Ravikar Patel, CGC For State : Mr. Ajay Kumrani, Panel Lawyer 2 Hon'ble Shri Justice Rakesh Mohan Pandey Order on Board 02.09.2026 1. By way of this petition, the petitioner has sought the following relief(s):- “10.1 Directing respondent no. 1 to dispose of the stay application/application filed under Section 220(6) of the Act not to 1 treat assessee/petitioner in default in adherence with the guidelines laid down in KEC International Ltd. vs. B.R. Balakrishnan (2001) 251 ITR 158 and appeal filed under Section 246A of the Act i.e. Annexure "P-2"(Colly) as expeditiously as it is feasible. 10.2 Directing respondent authorities not to resort to any coercive measure for recovery of demand raised vide Annexure "P/I"(Colly) till the disposal of the stay application/application filed under Section 220(6) of the Act not to treat assessee/petitioner in default or appeal filed under Section 246A of the Act i.e. Annexure "P-2" (Collv)whichever is earlier. 10.3 Alternatively staying effect and operation of Annexure "P/1" (Collv) till the disposal of the stay application/application filed under Section 220(6) of the Act not to treat assessee/petitioner in default or appeal filed under Section 246A of the Act i.e. Annexure "P-2" (Colly) whichever is earlier (the aforesaid relief is prayed for as an alternate to relief 10.2 prayed for vide the present petition). 10.4 Any other relief(s) that this Hon'ble Court may deem fit in facts and circumstances of the present case.” 2. It is pleaded by the petitioner that assessment was completed by the respondent authorities under Section 153C read with Section 143 (3) of the Income Tax Act, 1961 and on 28.03.2023 a demand of Rs.21,73,940/- was raised. Against demand raised by the respondent authorities an appeal was preferred before the respondent No.1 in 3 Form No. 35. An application for grant of stay was also moved u/s. 220 (6) before the respondent No.1, but till date application for grant of stay has not been considered and decided. 3. On the other hand, learned counsel appearing for respondents No. 1 to 3 would oppose. 4. Heard. 5. Having considered limited prayer made by learned counsel for the petitioner, this petition is disposed of with a direction to the respondent No.1 to decide application for grant of stay moved by the petitioner along with memo of appeal expeditiously, preferably within a period of 60 days from today. 6. Pending Interlocutory application(s), if any, stands disposed of. 7. With the aforesaid observation(s), and direction(s), the instant petition is hereby disposed of. 8. Registry is directed to communicate this order to the petitioner. Sd/- (Rakesh Mohan Pandey) JUDGE Nadim