The assessee has preferred an application on 3rd May, 2023 before the Asstt. CIT, for grant of stay against outstanding demand by filing an application under S. 220(6) contending that the demand raised in assessment is high pitched and it is not possible for the assessee to pay even 20 per cent of the disputed demand because the assessee does not possess enough resources to pay 20 per cent of the demand relying upon the circulars which was considered favorably by providing installment facility. Thereafter he has preferred an application before the Principal CIT reiterating the same which has been further considered and the installment was reasonably reduced vide order dt. 11th Dec., 2023. The record of the case would clearly demonstrate that the assessee has not prayed for waiver of 20 per cent of assessed tax liability by before the appellate authority. The circular issued by the Department cannot overwrite the power of the appellate authority, quasi judicial authority deciding the merit of the appeal/interim application for stay as the circulars are self imposed Departmental restraint on the demand/recovery to be raised/persuaded, which cannot affect the statutory power conferred upon the appellate authority. The assessee has not substantiate genuine hardship by placing materials or evidence. Writ petition is dismissed.  Followed, Amolak Singh Bhatia v. PCIT  (2020) 316 CTR 680 / 193 DTR 385  (Chhattisgarh)  (HC). (AY. 2018-19)