S. 220 : Collection and recovery-Assessee deemed in default-High-pitched assessment-Pre-deposit of 20 per cent. of assessed tax-Discretion to waive pre-deposit, Effect of CBDT circular. Circular cannot override powers of appellate authority-Commissioner considering facts and rejecting application but granting facility of paying tax in instalments-Circular cannot override powers of appellate authorities-CBDT Instruction No. 96, dated 21-8-1969-Writ petition dismissed. [S. 119,220(6), 246, Art. 226]