Pre-deposit of 20% tax demand required for stay, not appealable u/s 246A; Article 226 challenge blocked.

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....Stay of demand - pre-deposit of 20% of the demand - This proceedings issued by the assessing authority is in tune with Section 220(6) of the Act. Therefore, the petitioner need not construe that such insisting of 20% of the demand is a pre-deposit required for entertaining the appeal under Section 246A of the Act, but it is only a condition imposed by the assessing authority for grant of stay for the remaining amount of the demand under Section 220(6) of the Act. Therefore, for that reason the petitioner cannot once again challenge the impugned assessment order before this Court invoking the extraordinary jurisdiction under Article 226 of the Constitution of India. - HC....