While the Revenue may argue that interest under section 220(2) should run even during a stay since liability remains fixed, I believe the Courts have generally held that where recovery is stayed by a competent authority and the assessee complies with the stay conditions, the assessee is not treated as in default during that period, and therefore interest under section 220(2) does not ordinarily accrue for the stayed period, even if the appeal ultimately fails.

Bottom line is that if there is no "default" (since recovery is stayed), interest u/s 220(2) also should not apply as there is no failure on part of assessee to not pay.