Limitation exclusion for stay and pending appeals preserves correct computation of time for issuing GST tax orders. Periods of court or appellate stay and periods while departmental appeals are pending are excluded from computation of limitation for issuing tax orders. If fraud or suppression charges are not sustained by appellate fora, the proper officer must determine tax as if the notice were issued under ordinary deficiency provisions and adjust penalties accordingly; appellate modifications to tax require corresponding adjustments to interest and penalty. Opportunity for personal hearing, speaking orders, limits on adjournments, mandatory interest, recovery of self assessed tax, and bar on duplicate penalties are also provided.