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    <title>Department cannot initiate recovery proceedings against Assessee where Stay application is pending before Tribunal for the reasons not attributable to him</title>
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    <description>Departmental initiation of recovery proceedings is impermissible where an appeal with a stay application remains pending for reasons not attributable to the assessee; reliance on a departmental circular that was previously declared non est in such circumstances was held to be contrary to that principle, leading to a stay of recovery and issuance of a contempt notice against the officer who issued the demand.</description>
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      <description>Departmental initiation of recovery proceedings is impermissible where an appeal with a stay application remains pending for reasons not attributable to the assessee; reliance on a departmental circular that was previously declared non est in such circumstances was held to be contrary to that principle, leading to a stay of recovery and issuance of a contempt notice against the officer who issued the demand.</description>
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