https://www.taxtmi.com/caselaws?id=160312 Where a statute expressly bars stay of recovery of tax and penalty during revision, the High Court's residual power to issue directions as to payment cannot be read as a power to suspend enforcement. The later and specific embargo in section 22(6-A) prevails over the broader proviso to section 22(6), which is confined to regulating the manner of payment, including instalments or similar limited directions. Applying harmonious and purposive construction, the proviso must operate subject to the statutory prohibition on stay. The result is that no stay of recovery can be granted pending revision, although instalment relief may still be allowed. en-us Fri, 24 Sep 1999 00:00:00 +0530 Sat, 14 Dec 2013 13:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=160312 Where a statute expressly bars stay of recovery of tax and penalty during revision, the High Court's residual power to issue directions as to payment cannot be read as a power to suspend enforcement. The later and specific embargo in section 22(6-A) prevails over the broader proviso to section 22(6), which is confined to regulating the manner of payment, including instalments or similar limited directions. Applying harmonious and purposive construction, the proviso must operate subject to the statutory prohibition on stay. The result is that no stay of recovery can be granted pending revision, although instalment relief may still be allowed. Case-Laws VAT and Sales Tax Fri, 24 Sep 1999 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=160312