The Assessee filed an appeal before the CIT (A). Simultaneously, the Assessee filed a stay application before the Principal Commissioner, who disposed of the application by granting a stay until the disposal of the appeal, subject to the payment of 20 per cent of the demand amount. On writ  the Court observed that the  order had been passed without addressing the contentions raised by the Assessee regarding undue hardships arising from their financial condition and the downturn in the export industries. Additionally, the Court noted that neither the circular nor the office memorandum on dealing with demands raised in high-pitched demands had been considered. In this case, the Revenue had merely followed the instructions provided in the memorandum dated 29-2-2016 and 31-7-2017. The Court emphasized that these instructions and memorandum should not act as a constraint, and the authority, being a quasi-judicial entity, retains the discretion to issue a deposit order for less than 20 per cent. Since the order lacked reasoning and explanation, the Court quashed and set aside the order. The Court directed the authority to issue a fresh order after  considering the facts, circumstances, and submissions made by the Assessee. CBDT Instruction No. 1914 dated 21-3-1996, 29-2-2020 and 31-7-2017.  (AY. 2014-15, 2016-17, 2020-21)