High-value Additions made on uncorroborated and untested statements of third parties ought to stay as held by Bombay High Court in  435 ITR 151 (Bom). Moreover
Considering the financial condition of the petitioner the entire demand was stayed brushing aside the mechanical approach in directing the petitioner to pay 20 percent. of the tax demand or providing installments.
The High Court held that the AO ought to have considered the prima facie case, the balance of convenience, and financial hardship, if any, of the petitioner all of which aspects have been ignored