W.P.(C) NO.8210 of 2020 02. 17.03.2020 defects as pointed out by Stamp Reporter are stated to have been removed. Mr. Jagabandhu Sahoo, learned Senior Counsel enters appearance on behalf of petitioner by filing Appearance Memo in Court today. Appearance Memo be kept on record. Heard Mr. Jagabandhu Sahoo, learned Senior Counsel for petitioner and Mr. S.S. Mohapatra, learned Senior Standing Counsel for Income Tax Department. present writ application is preferred against order passed by Commissioner of Income Tax (TDS), Bhubaneswar refusing total stay vide Annexure- 8. In impugned order, it has been ordered as follows :- .. Accordingly, after adjusting refund due balance amount shall be paid by assesse in two installments. first being of Rs.50 lakhs on or before 29.02.2020 and balance in second installment on or before 15.03.2020. Thus 20% of total demand comes to Rs.2,84,37,116/-. Balance demand is stayed subject to payment of installments till 30.09.2020 or receipt of appellate order whichever is earlier. grievance of Mr. Jagabandhu Sahu, learned Senior Counsel appearing for petitioner is that, much amount has been taken by revenue by way of adjustment and such amount comes to Rs.1.99 Crores. In view of such fact, there is no need of further payment as per impugned order vide Annexure- 8. Having perused impugned order and taking into consideration submissions advanced by parties and affidavit filed by revenue, we are of view that, much time has been granted to petitioner to pay Rs.1 Crore in two installments of Rs.50 lakhs each. Only because question raised by petitioner before revenue is identical to question decided in CIT (TDS), Jaipur vs. M/s. Idea Cellular Ltd., in ITA No.205 of 2005 disposed of by Rajasthan High Court being followed by this Court in ITA No. 9 of 2012, we are not inclined to interfere with impugned order, specially when there is no ratio in case decided by this Court in ITA No.9 of 2012. petitioner is obliged to deposit amount as per order in Annexure- 8 and in final appeal, if it is found that revenue has collected more amount than demand, same be refunded to petitioner within period of fifteen (15) days from date of passing of appellate order. Let appeal pending vide Annexure- 2 be disposed of within period of six months from date of receipt of certified copy of this Order. It is made clear that, whatever money revenue has taken by way of adjustment or attachment, shall be refunded on substraction of payment ordered to be made. With aforesaid observation, writ application is disposed of. Urgent certified copy of this Order be granted as per rules. . C.R. Dash, J. .. S.K. Panigrahi, J. Subha Vodafone Idea Ltd. v. Asst. Commissioner of Income-tax (TDS) / Commissioner of Income-tax, TDS