The assessee filed the writ against the recovery  when the appeal was pending before the Appellate Tribunal  . The Court held that  the sequence and events revealed that the assessee had rightly approached the appellate authorities challenging the cancellation of registration under section 12AA as well as the orders of assessment dated March 28, 2013. The litigation was now pending before the Appellate Tribunal, the final fact finding authority. There was no avenue to interfere with the orders of assessment at this juncture, also because the orders of assessment stood telescoped into appellate orders passed by the Commissioner (Appeals) and by the Tribunal. The second limb of the prayer in the writ petitions was to direct the Tax Recovery Officer not to take coercive action till the disposal of the writ petitions. The interests of justice would be served if the Tribunal took up the stay petitions for hearing and disposal forthwith. As regards the attachment of the movables, the buses were used to facilitate the movement of students between their homes and the college. Students should not be made to suffer on account of the conflict inter se the assessee and the Department. Thus, while the attachment dated February 7, 2019 would continue, the Department was directed to release the buses to the assessee solely for use in college activities.( AY.2010-11, 2011-12)