Dismissing the petition the Court held that  the assessee had not presented any documents showing its financial incapacity to pay 20 per cent. of the demand. The issue of whether the purchases were genuine was a question of fact to be determined on the facts of each particular case. The assessee had attempted to delay the recovery proceedings of 20 per cent. demand and had not made out a case for a complete stay of demand. Order of Commissioner  affirmed. (AY. 2021-22)