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HC granted temporary stay on tax demand arising from appellate order based on Finance Ministry Circular regarding recovery guidelines pending formation of GST Appellate Tribunal. Prima facie case established by petitioner led to unconditional two-week stay on demand from July 24, 2024 order. Court directed filing of affidavit-in-opposition within six weeks with one week for reply. Decision acknowledges administrative gap due to pending constitution of Appellate Tribunal and applies interim protection mechanism in line with ministerial guidelines on recovery procedures.