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HC granted interim stay on appellate order demanding tax recovery. Stay conditional on petitioner paying 10% of disputed tax balance within two weeks, in addition to amounts already deposited u/s 107(6). Court noted absence of constituted Appellate Tribunal as material factor. Petitioner established prima facie case warranting temporary relief. Initial unconditional stay granted for two weeks, with extension contingent on additional payment. Stay to continue until writ petition disposal or further orders. Respondents directed to file opposition within six weeks, with one week allowed for reply. Matter to be heard on merits given institutional gaps in appellate mechanism.