The assessee moved application for stay of demand. The AO directed the assseee to deposit 20% of tax in dispute relying on the Circular of CBDT dated July 31, 2017 (2017) 396 ITR 55 (St)). On writ    the court set aside the order passed by the Assessing Officer to the effect that the assessee would not be treated as being in default if it deposited 20 per cent. of the outstanding demand and remanded the matter back to the Commissioner (Appeals) for a fresh decision in accordance with law after complying with the principles of natural justice on the prayer for stay made by the assessee and stayed the demand pursuant to the assessment order dated December 21, 2019 till such time. Matter remanded.  Court observed that  Commissioner (Appeals) being Quasi-Judicial Authority is not bound by  administrative circulars issued by  Central Board Of Direct Taxes.  Referred PRCIT v. LG  Electronics India Pvt. Ltd. [2018] 12 ITR-OL 334 (SC). (AY.  2017-18)