On writ the Court held that while requiring the assessee to pay 20 per cent. of the disputed payment by October 19, 2022, his request for stay of the demand had been rejected without even awaiting compliance of such requirement which vitiated the entire proceedings. The order rejecting the stay of demand was set aside. The matter was remitted to the Assessing Officer for decision afresh after considering each of the contentions raised by the assessee including additional submissions that were made on December 12, 2022 and passing a reasoned order on the merits and in accordance with law.