While directing the petitioners to register and pay current VAT dues, the Court kept past‑period liability in abeyance pending departmental scrutiny. The interlocutory application was accordingly disposed of.

The Tribunal observed that revenue has compared the figures reflected in the ST-3 returns and figures reflected in Form 26AS statement and raised the demand without further examining the reasons for the difference in the two statements.

Finding that the borrowers had voluntarily agreed before the DRT that auctioning one mortgaged property would satisfy Canara Bank’s dues, the Court ruled that such consent amounted to a waiver of objections relating to valuation, publication, and compliance with Rules 8 and 9 of the SARFAESI Rules. The Court also upheld the bank’s NPA classification as compliant with RBI’s 90‑day IRACP norms.