The Assessee challenged the dismissal of the stay application and the direction to deposit 20% of the total outstanding demand. The Court noted that the requirement to deposit 20% of disputed tax demand is not a pre-requisite for putting the demand in abeyance for all first appeals in all cases. The same has been noted by the Office Memorandum dated 29-02-2016 that the said pre-condition of deposit of 20% of the demand can be relaxed in appropriate cases. The authorities shall consider three basic principles, i.e., the prima facie case, the balance of convenience, and irreparable injury while disposing of the stay application. Consequently, the impugned stay order is set aside, and the matter is remanded for fresh adjudication after granting an opportunity to be heard.  (AY.  2013-14 to 2020-21)