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<h1>Limitation exclusion for stayed proceedings preserves computation periods and maintains enforceability of tax, interest and recovery obligations.</h1> Periods of stay or appellate litigation are excluded from computation of limitation for tax determination; if enhanced-charge notices requiring proof of fraud are held unsustainable, tax shall be determined under standard provisions. Orders directed by appellate bodies must be issued within two years. Procedural safeguards include a right to hearing on written request, limited adjournments, reasoned orders, prohibition on demands beyond notice grounds, automatic interest on short-paid tax, adjustment of interest and penalty following appellate modification, recovery of unpaid self-assessed tax under recovery provisions, and prohibition on duplicate penalties for the same act.
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