Coercive recovery barred while stay petition is pending before appellate authority until it is decided.

Coercive recovery steps should not be pursued while a statutory appeal and stay petition remain pending before the appellate authority, because procedural fairness requires the authority to await a decision on the stay request. The respondent was directed to defer coercive action until the appellate authority considers the stay petition.

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Issues: Whether coercive recovery steps could be taken while the statutory appeal and stay petition were pending consideration before the appellate authority.

Analysis: The petitioner had filed an appeal against the assessment order along with a stay petition. In these circumstances, procedural fairness required the authorities to await the appellate authority's decision on the stay petition before taking further coercive action.

Outcome: The respondent authority was directed to defer coercive steps until the stay petition is considered by the appellate authority.

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