Demand stayed against local authority as it wasn't taxed earlier and now it was taxed only via provi

IT: Where for prior period, income of assessee, a local authority constituted under provisions of Gujarat Town Planning and Urban Development Act, 1976, had been assessed at nil and it was sought to be brought into tax dragnet only by resorting to proviso to section 2(15), it should be granted stay of demand till disposal of appeal against assessment order by Commissioner (Appeals)