Pending statutory appeal, coercive tax recovery was stayed for the balance demand and bank attachment was lifted in part.

While the statutory appeal against assessment remained pending, the Court addressed whether demand recovery and consequential bank attachment should continue. It considered that part of the demand had already been recovered through withdrawal from the petitioner's bank accounts and, to balance the interests of justice, protected the petitioner from further coercive recovery for the balance amount until the appeal was decided. The Court also directed expeditious disposal of the appeal within twelve weeks and raised the bank attachment to that extent.

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Issues: Whether, pending disposal of the statutory appeal against the assessment, the demand and consequential bank attachment proceedings should be interfered with and whether partial stay of recovery ought to be granted.

Analysis: The appeal against the assessment was still pending. The demand amount had already been recovered in part by withdrawal from the petitioner's bank accounts. In these circumstances, the Court considered that the interests of justice would be served by directing expeditious disposal of the statutory appeal and by protecting the petitioner from further coercive recovery for the balance demand until the appeal was decided.

Conclusion: Relief was granted in part by directing disposal of the appeal within twelve weeks, staying recovery of the remaining demand, and raising the attachment to that extent.

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