Appeals procedure: requirements for pre deposit and stay of recovery govern filing and hearing before the Appellate Authority. Appeals to the Appellate Authority lie against adjudicating authority orders; the Commissioner may direct review and filing of applications as appeals. An appellant must satisfy a statutory pre deposit requirement-paying admitted amounts in full and depositing a portion of the remaining tax-after which recovery of the balance is stayed. The Appellate Authority must afford hearing, permit limited extensions and amendment of grounds for non wilful omission, and finally pass a reasoned written order confirming, modifying or annulling the impugned order, subject to procedural safeguards before enhancing liabilities.