Held, dismissing the petition, that the power vested under section 220(6) is discretionary and it is not mandatory to direct a predeposit of 20 per cent. of the assessed amount to obtain stay of deposit at the stage of filing the appeal before the Commissioner (Appeals). The Assessing Officer in the assessment order had given a number of cogent findings against the assessee. The Assessing Officer after analysing a number of relevant facts had held that the transaction between the assessee and the foreign entity was based on “reverse engineering”. The assessee had not been able to make out a prima facie case in its favour. The assessee’s plea of financial stringency based on its balance-sheet did not inspire confidence as according to the Assessing Officer, the-accounts had not been properly maintained. The court however observed that its view in the writ proceedings should not prejudice either of the parties at the stage of the appellate proceedings.