Section 220 – Income-tax Act does not provide for any precondition for grant of stay of recovery; where a stay application u/s 220(6) has been filed before AO, AO would dispose of same only upon consideration of three factors viz. prima facie case, financial stringency and balance of convenience.
Karangipully Vinothkumar v. Income-tax Officer – [2023] 146 taxmann.com 418 (Madras).