Pending statutory appeals protect taxpayers from coercive recovery until appellate authorities dispose of challenged assessment orders expeditiously.

Pending statutory appeals against assessment orders must be decided expeditiously to preserve the effectiveness of the appellate remedy. Where appeals have remained undisposed without recorded reasons, coercive recovery based on the challenged assessment orders should not be initiated until their disposal. The protection ensures that recovery action does not undermine the pending appellate process while the appellate authority determines the merits of the assessments.

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Issues: Whether recovery proceedings may continue while the statutory appeal against the assessment orders remains pending.

Analysis: The statutory appeals had remained pending since 2019, with no reasons recorded for their non-disposal. To preserve the efficacy of the pending appellate remedy, the appellate authority was directed to decide the appeals expeditiously, and recovery pending such decision was protected against coercive action.

Conclusion: Coercive recovery pursuant to the assessment orders shall not be initiated until disposal of the pending appeals.

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