Assessee’s application for interim stay of recovery of demand was disposed of with a conditional order to pay 20 per cent of tax demand made by Assessing Officer relying wholly on CBDT instruction no. 1914, dated 21-3-1996. PCIT also confirmed said order without even hearing assessee. Allowing the petition the Court held that, since no speaking order was passed by revenue authorities while directing assessee to deposit 20 per cent of demand amount and impugned order was passed relying wholly on CBDT instruction no. 1914, dated 21-3-1996, impugned order being mechanical and passed without application of mind was to be set aside and matter was to be remanded back for disposal afresh .