Court held that the AO has to consider the case of the particular assessee on the merits and if he comes to the conclusion that the assessee has a case for grant of stay, then subject to deposit of 20 per cent. of the disputed demand, the outstanding demand may be stayed and in certain cases. The condition of pre-deposit of 20 per cent. of the disputed demand is neither contemplated by the memorandum nor is there legislative sanction mandating such deposit for hearing of an application for stay. Directed to follow the guidelines prescribed by the Bombay High court in UTI Mutual Fund v. ITO (2012) 345 ITR 71 (Bom.)(HC)  KEC International Ltd v. B.R. Balakrishnan (2001) 251 ITR 158 (Bom.)(HC), Coca Cola India P. Ltd. v. Add. CIT (2006) 285 ITR 419 (Bom.)(HC)