The assessee challenged a high-pitched assessment order computing the income which was 51 times the returned income, raising a demand under section 156 of the Income-tax Act, 1961 which was 180 times the self-assessed tax paid by the assessee for the assessment year 2018-2019. A statutory appeal was preferred before the Commissioner (Appeals). The application filed under section 220(6), seeking stay of recovery was rejected by the Assistant Commissioner who permitted payment of 20 per cent. of the demand in monthly instalments. The Principal Commissioner partly modified the order but retained the 20 per cent. deposit requirement for proceeding with the appeal before the Commissioner (Appeals). These orders were upheld by the court in the writ petition filed by the assessee. On appeal  allowing the appeal, that considering that the statutory appeal under section 246A had been pending before the Commissioner (Appeals) for one year and five months and that the assessee had already deposited Rs.41.55 lakhs and the grant of stay of recovery, under section 220(6), in the interim order of the court being in force for the past five months, the appellate authority was directed to decide the appeal within three months and to continue the interim protection until the outcome of the statutory appeal. The order in the writ petition was set aside.(AY. 2018-19)