The party is walking through the forest at night when they come upon a clearing. Half a dozen black-robed corpses lie scattered across the ground, and a pentagram of blood is shoddily drawn in the dirt.
It seems these people summoned something they could not control. Whether or not the demon returns is up to the GM, but it would be just as rich if the demon never returned, and for the rest of the night, every stray sound or odd shadow will be jumped at!
Rather than making a baddy impossible to hit, consider giving it mega-hit points.
Super hard to hit leads to great player frustration. Allowing them to do damage leads to a sense of accomplishment. another variation of this would be to give the bad guy a forcefield that shows damage.You could also give them a mastermind ability that sluffs the damage of to minions who should be easy to kill.Once in a while a super high to hit encounter is ok ,but it should be few and far between.
Your mileage may vary