Pending tax liability: High Court grants limited interim protection and directs expeditious disposal of the appeal.

Pending determination of the tax liability in the first appeal, the High Court balanced interim protection with revenue interests by granting only limited relief during the interregnum. It directed expeditious disposal of the appeal on merits and required a reduced cash deposit together with security for the balance amount, so that recovery was not pursued beyond the limited conditions imposed until the appellate authority decided the matter.

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Issues: Whether, pending disposal of the first appeal, the revisionist was entitled to further protection against recovery of the disputed tax and an expeditious decision of the appeal.

Analysis: The tax liability was yet to be determined in the pending first appeal. In the interests of justice, the matter required early adjudication on merits. The Court therefore directed the appellate authority to decide the appeal expeditiously, and, for the interregnum, balanced the equities by requiring only a limited cash deposit and security for the balance amount.

Conclusion: The revisionist was granted limited interim relief by way of a reduced deposit and security, and the pending appeal was directed to be decided expeditiously.

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