https://www.taxtmi.com/caselaws?id=799533 Recovery of a tax demand pending a first appeal may be stayed where aggregated and apparently repetitive import information, without invoice-wise or bill-of-entry-wise details, prevents meaningful reconciliation with the assessee's complete accounting records. Such circumstances create a strong prima facie concern of breach of natural justice; a high-pitched assessment and resulting undue hardship further support protection from recovery. Administrative memoranda requiring payment of 20% of the demand do not restrict the Court's power to grant an appropriate stay, and no deposit need be imposed where the facts justify full protection. The appellate authority must decide the appeal promptly and independently on its merits. en-us Fri, 18 Sep 2026 00:00:00 +0530 Wed, 23 Sep 2026 08:48:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799533 Recovery of a tax demand pending a first appeal may be stayed where aggregated and apparently repetitive import information, without invoice-wise or bill-of-entry-wise details, prevents meaningful reconciliation with the assessee's complete accounting records. Such circumstances create a strong prima facie concern of breach of natural justice; a high-pitched assessment and resulting undue hardship further support protection from recovery. Administrative memoranda requiring payment of 20% of the demand do not restrict the Court's power to grant an appropriate stay, and no deposit need be imposed where the facts justify full protection. The appellate authority must decide the appeal promptly and independently on its merits. Case-Laws Income Tax Fri, 18 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799533