In the matters of recovery of demands the Telangana High Court in  457 ITR 560 (Telangana) taking note of Supreme Court decision in  12 ITR-OL 334 (SC) held that It is trite law that when an Income-tax authority like AO , CIT, CIT (A) exercises jurisdiction under section 220(6) of the Act, he exercises quasi-judicial power.
While exercising quasi-judicial powers, the authority is not bound or confined by Departmental instructions. He has to apply his mind which must be reflected in the order.
Any order imposing 20% condition in defiance of this maxim would not be in accordance with law and shall call for challenge.
The CBDT should issue a circular instruction stating that their previous circulars dated 29 feb 16 and July 31 2017 are no hard and fast rule citing and that AO should apply his own mind to each case demand resolution.