Assessee filed an appeal against an assessment order dated 29.12.2023 and subsequently petitioned for a stay, which was rejected due to non-payment of required 20% deposit per CBDT’s office memorandum in F.No.404/72/93-ITCC dated 29.02.2016 and F.No.404/72/93-ITCC dated 31.07.2017-A second stay petition was dismissed by Commissioner of Income Tax (TDS)-Assessee then filed a writ petition contending they could demonstrate financial stringency if given another opportunity. Court held that  CBDT’s office memorandum serves as guidelines for deciding stay applications and these guidelines do not replace need to assess whether applicant has established a prima facie case, balance of convenience, and financial stringency and since impugned order overlooked those considerations, interference was warranted. Since stay petition filed by assessee did not contain details relating to financial stringency, it was necessary to impose costs on assessee subject to payment of a sum of Rs.10,000/-assessee would be permitted to submit a fresh stay application before assessing officer. CBDT’s office memorandum in F.No.404/72/93-ITCC dated 29.02.2016 and F.No.404/72/93-ITCC dated 31.07.2017. (AY. 2016-17 to 2020-21)