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Issues: Whether the Tribunal could continue the earlier stay order during the pendency of the reference application before the High Court.
Analysis: The Tribunal noted that the applicants had already deposited a substantial amount under the earlier stay order and that the reference application had been allowed by the High Court. Relying on the principle that, during reference proceedings, the High Court acts in an advisory or consultative jurisdiction and the matter remains pending before the Tribunal, the Tribunal held that it had power to extend the stay.
Conclusion: The stay order was extended and directed to remain in force until final disposal of the reference application by the High Court, in favour of the assessee.
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