AO passed an assessment order raising huge tax demands against assessee towards additions made in respect of bogus unsecured loan received by it and bogus investment in properties made by it .  Assessee filed appeals before CIT  (A) and approached Assessing Officer and requested for stay of demand pending such appeals . AO  directed the assessee to deposit 20 per cent of disputed tax demand, upon which, recovery of remaining amount would be stayed.  Assessee contended that this being a case of high pitched assessment, he should not be asked to deposit his 20 per cent of total amount as it was beyond his financial capacity . Court held that it is inbuilt in circular dated 29-2-2016 itself to either decrease or even increase percentage of disputed tax demand to be deposited for an assessee to enjoy stay pending appeal . Therefore in view of fact that total tax demand was quite high and issues were at first appeal stage and even 20 per cent of tax dues would run into lakhs of rupees, requirement of depositing disputed tax dues to enable assessee to enjoy stay during pendency of appeal before  CIT (A) was to be reduced to 10 per cent.