If you have to hold all the data in memory, then in many ways the choice is arbitrary. If you have existing code that operates on Stream, then MemoryStream may be more convenient, but if you return a byte[] you can always just wrap that in a new MemoryStream(blob) anyway.
It might also depend on how big it is and how long you are holding it for; MemoryStream can be oversized, which has advantages and disadvantages. Forcing it to a byte[] may be useful if you are holding the data for a while, since it will trim off any excess; however, if you are only keeping it briefly, it may be counter-productive, since it will force you to duplicate most (at an absolute minimum: half) of the data while you create the new copy.
So; it depends a lot on context, usage and intent. In most scenarios, "whichever works, and is clear and simple" may suffice. If the data is particularly large or held for a prolonged period, you may want to deliberately tweak it a bit.
One additional advantage of the byte[] approach: if needed, multiple threads can access it safely at once (as long as they are reading) - this is not true of MemoryStream. However, that may be a false advantage: most code won't need to access the byte[] from multiple threads.
Bytearray then are you creating a newMemoryStreameverywhere you use it?