When the appeal is pending before the CIT(A)  the assessee  filed application for stay of demand. Assessing Officer directed assessee to make payment of 20 per cent of outstanding demand. On writ the  assessee submitted that depositing 20 per cent of disputed amount would result in enormous financial burden/stress and would effect day to day functioning of assessee. Court held that in view of exceptional circumstances as noted in Office Memorandum dated 29-2-2016, assessee was directed to make payment of a sum of Rs.40 lakhs and demand was to be stayed till disposal of appeals.CBDT Instruction No.1914, dated 2-2-1993 and Office memorandum dated 29-2-2016. (AY. 2019-20)