Exclusion of judicial stay from limitation periods affects computation of tax determination timelines and recovery procedures.

Periods of judicial or appellate stay are excluded when computing limitation for issuing tax notices and orders. If a fraud-based notice is held unsustainable, the proper officer must determine tax as if a standard notice were issued, and orders required by appellate directions must be issued within two years. Appellate delay on related legal issues is excluded from limitation where further appeal is pending. Interest on short-paid tax is payable regardless of its mention in the order, and modification of tax by appellate bodies adjusts interest and penalty accordingly.

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