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Issues: Whether interference under Article 226 was warranted against the Tribunal's dismissal of the stay application where the duty had not yet been quantified and no penalty had been imposed.
Analysis: The petitioner challenged only the refusal to grant stay of the appellate order. The operative order before the Tribunal had merely dismissed the appeal of the Commissioner (Appeals), and no demand had been raised against the petitioner under that order. Since the petition did not seek stay of the original adjudication order and the impugned appellate order itself did not require execution of any quantified demand, there was no basis for grant of stay or for writ interference.
Conclusion: Interference under Article 226 was not justified and the writ petition was dismissed.