JUDGMENT Akil Kureshi, J. - These petitions arise in common background. We may refer facts from Writ Petition (L) No. 810 of 2019. 2. The petitioner is a trust. The object of the trust is to acquire Non-Performing Assets ("NPAs" for short) by banks and recover dues from the defaulters. For the assessment year 2016-17, the Assessing Officer passed an order of assessment on 24.12.2018 making certain disallowances and additions in the hands of the assessee which has given rise to a tax demand of Rs. 6.69 crores (rounded off). Against such order of assessment, the petitioner has filed an appeal before the Commissioner (Appeals) on 16.1.2019. Pending such appeal, the petitioner first requested the Assessing Officer to keep tax demand in abeyance. The Assessing Officer passed an order on 13.2.2019 directing the petitioner to deposit 20% of the tax demand, upon which the rest of the recovery would be stayed. The petitioner thereupon approached the Principal Commissioner of Income Tax and requested for full waiver of recovery. The Commissioner rejected such a petition by the impugned order dated 5.3.2019. Against this order, the petition has been filed. In other petitions, though figures are varying, the facts are common. 3. Learned counsel for the petitioner pointed out that the additions made by the Assessing Officer in the present set of assessment orders were made in hands of other similar trusts created under ARCIL. Such order of assessment was challenged before the CIT(A) and by his order dated 3.1.2018, the appeal of the assessee was allowed and all the additions made by the Assessing Officer were deleted. When this fact was brought to the notice of the Commissioner while requesting for stay, the Commissioner in the impugned order, observed that such order of the appellate Commissioner has not been accepted by the Revenue and in other cases, no appeal could be filed due to low tax effect. 4. It would prima facie appear that the assessment orders in the present case are based on same additions and disallowances which under similar if not identical circumstances, have been deleted by the appellate Commissioner which order as of today holds the field. Under the circumstances, it would prima facie appear that no recovery pending the appeal before the appellate Commissioner could be carried out. Under the circumstances, it would prima facie appear that no recovery pending the appeal before the appellate Commissioner could be carried out. This Court in the case of UTI Mutual Fund vs. Income Tax Officer [2012] 19 taxmann.com 250/206 Taxman 341/345 ITR 71 had observed that, "If the Assessing Officer has taken a view contrary to what has been held in the preceding previous years without there being a material change in facts or law, that is a relevant consideration in deciding the application for stay.". 5. In the present case, prima facie, the Revenue is unable to point out any material change in the facts or law on the basis of which the Assessing Officer has made the additions. 6. Under the circumstances, while allowing the Revenue to file reply and adjourning this group of petitions to 22nd March, 2019, we prevent the respondents from carrying out recoveries arising out of the orders of assessment.