Right of appeal requires partial payment before filing and stays recovery pending appellate determination, subject to time limits. Appeals lie to the prescribed Appellate Authority within three months; the Commissioner may refer matters to the Appellate Authority within six months. Appeals must meet prescribed form and a payment precondition-full payment of admitted amounts and payment of a further portion of disputed tax-upon which recovery of the balance is stayed. The Appellate Authority will hear parties, may allow limited adjournments and additional non-wilful grounds, and may confirm, modify or annul orders (but not remit). Written reasoned orders must be issued, communicated to parties and tax authorities, and are final subject to specified sections.