Interim protection in tax dispute: registration and return deadlines extended, with coercive recovery stayed subject to final adjudication.

Time limits under the trade circular were extended, and an interim arrangement was made to protect developers from coercive recovery of tax, interest, or penalty pending final disposal. The arrangement preserved the revenue's right to complete assessment and treated any payment by developers as subject to the final decision. It also provided that, if the amendment to section 2(24) of the Maharashtra Value Added Tax Act, 2002 were ultimately struck down, any amount returned by the State would carry interest as ordered at final disposal.

---

---

Issues: Whether interim relief was warranted by extending the time for registration and return filing under the trade circular and by staying coercive recovery of tax, interest, or penalty pending final disposal.

Analysis: The Court recorded the statement that the time limits prescribed in the trade circular would be extended, and, on that basis, fashioned an interim arrangement to protect the developers while preserving the revenue's right to complete assessment. The arrangement also provided that payment made by the developers would remain subject to the final decision in the matter and that, if the amendment to section 2(24) of the Maharashtra Value Added Tax Act, 2002 were ultimately struck down, any amount returned by the State would carry interest as ordered at final disposal.

Conclusion: The time for registration and filing returns was extended, coercive recovery was stayed on the stated conditions, and the interlocutory application was disposed of.

---