High pitched assessment was made on the assessee. The assessee filed an appeal before the CIT(A). When the appeal was pending the assessee filed an application for stay before the PCIT. PCIT rejected the stay application. On writ allowing the petition, the Court held that the Principal Commissioner had not considered the matter in the proper perspective and had mechanically declined to grant stay of recovery of disputed demand as prayed for by the assessee. When the assessee had submitted to the Principal Commissioner that it was a high pitched assessment it could not have been dismissed by the Principal Commissioner by merely saying that the issue had been discussed threadbare during the assessment proceedings. The finding recorded by the Principal Commissioner was that the assessment order was passed by the Assessing Officer after granting sufficient opportunities and after due consideration of all the relevant aspects of the matter and, therefore, the issue of high pitched assessment need not be considered. The orders passed by the Principal Commissioner were set aside and he was directed to consider the application filed by the assessee under section 220(3) and 220(6) afresh in conformity with all the Central Board of Direct Taxes Instructions and the parameters laid down by providing an opportunity of being heard to the assessee and pass orders in accordance with law. Court also held  that the assessees could file applications before the Commissioner (Appeals) seeking appropriate relief. Powers to grant stay of recovery can be implied as inherent power of the first appellate authority. (AY.  2010-11 to 2020-21)