TAXATION - garnishee notice - where garnishee notice issued during stay of enforcement of judgment in relation to taxpayer's liabilities and while tax appeal was being pursued - whether the debt pursued by way of the notice is separate from judgment debt subject to stay - where new information had been obtained after the stay proceedings - whether decision to issue notice affected by jurisdictional error - whether decision maker failed to take into account relevant considerations or took into account irrelevant considerations - whether decision to issue garnishee notice unreasonable
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