Honourable President of the Appellate Tribunal  to consider whether a Special Bench should be constituted to decide two very significant aspects relating to the powers of the Appellate tribunal  to grant unconditional stay of demand after the amendment in first proviso to S. 254(2A) by the Finance Act 2020, namely, (i) The legal impact, if any, of the amendment on the powers of the Tribunal u/s 254(1) to grant stay; and, (ii) if the amendment is held to have any impact on the powers of the Tribunal u/s 254(1),- (a) whether the amendment is directory in nature or is mandatory in nature; (b) whether the said amendment affects the cases in which appeals were filed prior to the date on which the amendment came into force; (c) whether, with respect to the manner in which, and nature of which, security is to be offered by the assessee, under first proviso to S.  254(2A), what are broad considerations and in what reasonable manner, such a discretion must essentially be exercised, while granting the stay,by the Tribunal.     (  SA Nos. 147 and 148/Mum/2020 ,arising out of ITA Nos 1423 and 1424/Mum/2018 dt 17 -06 -2020) ( AY. 2011-12 , 2012 -13 )