Bank guarantee compliance turned on proof of stay, appeal status, and supporting documents before the Tribunal.

Revenue could not justify withholding implementation of the Tribunal's earlier order and continuing the bank guarantee without showing a stay or reversal by the High Court; the matter was not finally decided. The Bench directed filing of an affidavit and supporting documents covering the appeal, stay application, any interim order, the relevance of the letter relied upon, and the status of the bank guarantee.

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Issues: Whether the Revenue could withhold implementation of the Tribunal's earlier order and continue the bank guarantee without demonstrating any stay or reversal by the High Court, and whether further particulars were required regarding the pending appeal and stay proceedings.

Outcome: The matter was not finally adjudicated; the Revenue was directed to place an affidavit and supporting documents before the Bench on the filing of the appeal, stay application, any interim order, the relevance of the letter relied upon, and the status of the bank guarantee.

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