Recovery stay extension granted where appeal delay was not attributable to the assessee and revenue security remained protected.

Stay of recovery of disputed tax demand was extended because the delay in disposing of the appeal was not attributable to the assessee. The assessee's challenges regarding the absence of a document identification number and limitation remained prima facie supportable, while Revenue's interests were protected by attached fixed deposits substantially exceeding the demand. Recovery remains stayed for 180 days or until disposal of the appeal, whichever occurs earlier.

---

---

Issues: Whether the stay of recovery of the disputed tax demand should be extended pending disposal of the appeal.

Analysis: The delay in disposal of the appeal was not attributable to the assessee. The challenges concerning the absence of a document identification number and limitation remained prima facie supported in the assessee's favour. Revenue's interest was adequately secured because fixed deposits substantially exceeding the disputed demand continued to remain attached.

Conclusion: The stay of recovery was extended for 180 days or until disposal of the appeal, whichever is earlier, in favour of the assessee.

---