Recovery stay extension continued where taxpayer caused no appeal delay and attached deposits protected revenue interests.

Extension of stay on recovery of disputed tax demand was considered where the appeal had not been delayed by the assessee. The notes identify prima facie support for challenges based on the absence of a document identification number and limitation. Revenue's interests were treated as adequately protected by attached fixed deposits exceeding the disputed demand. Recovery stay was extended for 180 days or until disposal of the appeal, whichever occurred earlier.

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

Analysis: The existing stay had repeatedly been continued, and no delay in disposal of the appeal was attributable to the assessee. The challenges concerning the absence of a document identification number and limitation remained prima facie supported by decisions favourable to the assessee. Revenue's interest was adequately protected because fixed deposits substantially exceeding the disputed demand remained 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.

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