SC : CBDT circular can't curtail CIT's 'quasi-judicial' authority to grant lesser deposit relief

SC clarifies that CBDT’s office memorandum (‘OM’) dated July 31, 2017 regarding stay of demand does not interfere with AO’s power to grant stay on deposit of a lesser amount, pursuant to Revenue’s appeal challenging Delhi HC judgment in LG Electronics India Pvt. Ltd.’s (‘assessee’) case; SC gives credence to Additional Solicitor General Vikramjit Banerjee's submission before it that the said administrative Circular of the CBDT will not operate as a 'fetter' on the Commissioner, since it is a quasi judicial authority; Disposing off Revenue’s appeal, SC clarifies that “in all cases…it will be open to the authorities, on the facts of individual cases, to grant deposit orders of a lesser amount than 20%, pending appeal.”:SC