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Issues: Whether the writ petition could be entertained in the absence of a constituted second appellate tribunal and whether interim protection could be granted against recovery of the remaining tax demand.
Analysis: The petition was entertained because the second appellate tribunal had not yet been constituted. The petitioner's request for access to the statutory appellate remedy was considered, and interim protection was granted subject to deposit of the entire tax demand within fifteen days.
Outcome: Interim stay was granted against the remaining demand during pendency of the writ petition, subject to deposit of the entire tax demand.