Held, that a perusal of the order dated February 2, 2023, made it clear that the Commissioner (E) had merely followed the circulars of the Central Board of Direct Taxes and on the basis thereof had directed the assessee to pay 20 per cent. of the demand as a pre-condition for stay of the demand. The order was not valid. Directed to pass speaking order after considering the Judgement of Apex Court in PCIT v. LG Electronics India Pvt Ltd (2018) 12 ITR-OL 334 (SC) (AY.2016-17 to 2021-22)