After Tribunal upheld addition to book profit by treating capital expenditure debited to P&L account as liable to adjustment, assessee not entitled to unconditional stay merely on plea of strong prima facie case or high-pitched assessment.  CBDT circulars on high-pitched assessments mainly apply at first appellate stage.Pending rectification application reducing demand justified limited departure from normal rule of full deposit.Interim stay granted subject to deposit of Rs. 60 crores within four weeks.Request to substitute bank guarantee rejected. In fiscal matters, bank guarantee is not an appropriate substitute for cash deposit and unconditional stay should ordinarily not be granted.