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Issues: Whether the Revenue could initiate coercive recovery and attachment proceedings during the pendency and reservation of orders on the stay petitions.
Analysis: The stay petitions had already been heard and orders reserved. In that situation, the Revenue was expected to await the Tribunal's decision on the stay applications before proceeding with recovery. The attachment notices issued under Section 142 of the Customs Act, 1962 were therefore treated as inappropriate.
Outcome: The attachment orders dated 8-9-2000 were stayed and the Revenue was directed not to take further recovery action until the stay order became available.