2020 (3) TMI 1289

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....Shashank , Advocates For the Respondents : Y. V. Raviraj , Advocate JUDGMENT B. M. SHYAM PRASAD J.- 1. The learned counsel for the petitioner and the learned counsel, Sri Y. V. Raviraj, who accepts notice for the respondents Nos. 1 and 2 are heard. 2. The petitioner is aggrieved by the order dated February 26, 2020 passed by the Principal Commissioner of Income-tax, Hubballi, rejecting his ap....

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....of Income-tax in the light of Instruction No. 1914 and the subsequent Official Memorandum/Circular dated February 29, 2016, while considering an application for stay, had to consider whether the assessment by the Assessment Officer is an unreasonably high-pitched assessment and whether the petitioner is put to genuine hardship because of such assessment. The learned counsel for the petitioner reli....

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....ee if the assessee's case would fall under Instruction No. 2B(iii) of Circular No. 1914, or not? Both the Assessing Officer, and the Principal Commissioner of Income-tax, are required to examine whether the assessment is 'unreasonably high-pitched', or whether the demand for depositing 15 per cent. of the disputed demand amount 'would lead to a genuine hardship being caused to the ....