High pitched assessment of about 170 times higher than the returned income and raised a demand which was about 161 times higher.  The assessee filed an appeal before the Commissioner (Appeals) and sought stay of demand under section 220(6). The Assessing Officer, applying the Central Board of Direct Taxes’ office memorandum, directed a 20 per cent. redeposit. The review petition before the Principal Commissioner was rejected. The assessee then filed a writ petition, which was allowed with a direction to reconsider the stay application and decide the appeal expeditiously. The Principal Commissioner directed the assessee to deposit Rs. 5 lakhs per month until 20 per cent. of the total demand was deposited or the appeal was decided. On a writ petition, the Court held that until the appeal was decided by the appellate authority, the assessee was directed to pay a reduced monthly sum of Rs. 1 lakh, either until a smaller percentage of the outstanding demand was paid or the decision of the appellate authority was received, whichever was earlier. The assessee should not alienate or mortgage any immovable property owned by him without the prior written permission of the concerned jurisdictional Assessing Officer and this restriction shall be subject to the outcome of the appeal.(AY. 2022-23)