Assessee filed its returns for relevant years declaring certain taxable income. Assessment order was passed making certain additions .  Assessee filed an appeal under section 246A  along with an application seeking stay of demand . Stay application was disposed of with a direction to assessee to deposit 20 per cent of demanded amount . Hence, petition was filed Court held that the  order was passed by blindly following Office Memorandum (F.No. 404 /72 /93 -ITCC ] dt 31 -7 2017   and even no opportunity of hearing was given to assessee .Accordingly  order was set aside and, matter was to be remanded back to Commissioner (Appeals) to consider stay application afresh after affording an opportunity of hearing to assessee .  Circular No. 6, dated 29-02-2016 and office memorandum [F. No. 404/72/93-ITCC], dated 31-7-2017  (AY. 2017-18 ,  2018-19)