Prima facie stay relief upheld where input description was accepted and the limitation objection was treated as significant.

A prima facie case for unconditional stay was found where the applicants had correctly described the inputs and the department had accepted that description, even though the classification dispute remained unresolved. The plea of limitation was also treated as having force at this stage, and the Revenue's cited authorities were considered not directly relevant to the issue under consideration. On that basis, unconditional stay was granted.

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Issues: Whether the applicants had made out a prima facie case for unconditional stay, and whether the plea of time-bar affected the demand at this stage.

Analysis: The applicants had correctly described the inputs and the department accepted that description, though the classification dispute remained. The time-bar contention was also treated as having force, and the authorities cited by the Revenue were found not quite relevant to the issue under consideration.

Outcome: Unconditional stay was granted.

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