Petitioner fails to show genuine hardship; 20% deposit requirement by ACIT upheld due to lack of exceptional circumstances.

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....Stay of demand - ACIT requiring to deposit 20% of the outstanding demand - only in ‘exceptional circumstances’ the discretion of the AO could be interfered with by the superior authority i.e either the assessment order is unreasonably high-pitched or a genuine hardship is likely to be caused to the Assessee - Petitioner has failed to make out a case of genuine hardship - no stay of the demand....