The assessee was subjected to a tax demand of Rs. 4.94 crores. While its appeal was pending, the department granted a stay of demand conditional upon the deposit of 20 per cent of the said demand in monthly instalments of Rs. 4 lakhs. The assessee’s application for an out-of-turn hearing of the appeal, on the ground that the assessment was high-pitched, was rejected by the Local High-Pitched Committee. The High Court dismissed the assessee’s writ petition, holding that the Committee’s role is to form a prima facie view, not to adjudicate in depth, and its decision to deny an early hearing, based on the assessee’s non-compliance with notices, was not irrational. The Court further held that the department, by allowing the 20 per cent deposit to be paid in instalments, had acted in a “very reasonable and considerate” manner. Thus, the conditional stay order did not violate the principles of natural justice. CBDT Circular dated 29-12-2021; CBDT Instruction No. 1914, dated 21-3-1996; Office Memorandum (F. No. 404/72/93-ITCC) dated 31-7-2017; CBDT Instructions F. No. 225/101/2021-ITA-11, dated 23-4-2022. (AY. 2018-19)