Stay of an uncertain tax order pending appeal where adjudication was set aside without determining the duty demand.

The operation of an impugned order was stayed pending appeal where the challenged order had set aside the adjudication without quantifying the duty demand or directing the lower authorities to determine the correct demand, leaving the net effect uncertain. In that situation, interim protection was considered necessary to preserve the subject matter of the appeal until final disposal.

---

---

Issues: Whether the operation of the impugned order was liable to be stayed during the pendency of the appeal.

Analysis: The order under challenge had set aside the adjudication without quantifying the duty demand or directing the lower authorities to determine the correct demand, leaving the net result of the order uncertain. On that basis, the pending appeal required protection against the operation of the impugned order.

Outcome: The operation of the impugned order was stayed during the pendency of the appeal.

---