Assessee filed an appeal against assessment order and also filed an application seeking a stay of recovery of disputed demand.  AO  passed an order under S. 220(6) to pay 20 per cent of disputed demand of tax as a pre-condition for grant of stay of recovery .On writ the Court held that  grant of stay is conditional upon satisfaction of three primary aspects, i.e., existence of a prima facie case, financial stringency demonstrated and established by assessee and balance of convenience in matter . Since the AO proceeded mechanically in calling upon assessee to remit 20 per cent of demand without examining appropriateness of facts and circumstances of case order passed by the AO was set aside.   (AY. 2011-12 to 2017-18)