The assessee  is the Zoos and Parks Authority of the State. In terms of circulars dated February 29, 2016 and July 31, 2017 ([2017] 396 ITR (St.) 55) of the Central Board of Direct Taxes, the Commissioner (E) granted stay of demand subject to payment of 20 per cent. of the total demand for the assessment years 2016-17 and 2021-22. In the writ petition filed by the assessee against such order, the court remanded the matter back to the Commissioner (E) for passing a fresh order after giving due opportunity of hearing to the assessee. The Commissioner (E) passed a fresh order to the effect that the assessee had obtained a new permanent account number on December 22, 2014 under which it did not apply for registration under section 12A and that therefore, the assessee did not have a valid registration for the claim of exemption under section 11 of the Income-tax Act, 1961 during the period for which demands were raised and accordingly raised a demand. Appeals under section 246A were pending before the Commissioner (Appeals) for each of the assessment years. On a writ the Court held  that while the main issue as to entitlement of the assessee to exemption under section 11 was the subject matter of the appeals pending before the Commissioner (Appeals), considering the status of the assessee which had been taken note of by the Commissioner (E) himself, a deposit of Rs.3 crores being made by the assessee, the demand raised under section 156 for the assessment years 2016-17 to 2021-22 should remain stayed till disposal of the appeals stated to be pending before the Commissioner (Appeals). Ordered accordingly.  (AY. 2016-17 to 2021-22)