Discretion to defer tax recovery: ITO may treat disputed amounts as not in default subject to conditions and review. The ITO's discretion under section 220(6) permits treating an assessee as not being in default for disputed amounts while an appeal is pending; this is not a stay of demand and must be recorded in writing. The ITO must assess the legal and factual nature of disputed points, may impose conditions such as security, interim payments and an undertaking to cooperate, and should reserve a right to review the order to ensure compliance. Monitoring, withdrawal for breach, adjustment of refunds, higher approvals in certain cases, notification of significant stayed demands and application to other direct taxes are required procedural measures.