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Tax recovery and attachment cannot continue beyond the subsisting recoverable demand after appellate relief. The Court found that most demands underlying the tax recovery certificates had ceased to survive, and only the interest component relating to the quantum addition for A.Y. 2008-09 remained presently recoverable, while the penalty demand and interest thereon were stayed. The recovery certificates and attachments were therefore unsustainable except to the limited extent needed to protect the Revenue for the unstayed demand. Attachments over two properties were quashed, one property was allowed to remain attached, and the certificates were directed to be revised to reflect only the outstanding unstayed demand.
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