S. 220 : Collection and recovery – Assessee deemed in default –Pendency of appeal before CIT(A)- Stay of demand – The power of the AO to review the situation every six months, would not authorize him to lift the stay previously granted after full consideration and insist on full payment of tax without the assessee being responsible for delay in disposal of the appeal or any other such similar material change in circumstances.[ S.220(6) , 254(2A) ]