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      <description>Recovery of penalty was directed to remain stayed until the assessee&#039;s appeal before the Tribunal was decided, reflecting reliance on departmental instructions pending appellate disposal. The High Court also directed expeditious disposal of the appeal, linking interim protection to prompt adjudication on the merits. The operative effect was that coercive recovery was restrained during the pendency of the appeal, while the appellate forum was asked to decide the matter without delay.</description>
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