Modvat account debit can satisfy a Tribunal pre-deposit order when no cash-only condition was imposed.

Deposit by debit to the Modvat account was treated as valid compliance with a Tribunal pre-deposit direction where the Tribunal had already accepted the deposit made from the RG 23A account. The Commissioner could not challenge that acceptance or sit in judgment over it. Since the stay order did not require payment only in cash or through the personal ledger account, compliance through debit to the Modvat account remained sufficient. The cited authority was consistent with that position. The Commissioner's application was therefore without merit.

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Issues: Whether the deposit made by debit to the Modvat account could be treated as valid compliance with the Tribunal's pre-deposit order, and whether the Commissioner could question the Tribunal's acceptance of such compliance.

Analysis: The Tribunal had already accepted compliance after noting the deposit made by debit to the RG 23A account. The Commissioner could not sit in judgment over that acceptance. In any event, the stay order had not imposed any condition that the deposit must be made only in cash or through the personal ledger account. The cited authority supported the validity of payment by debit to the Modvat account.

Conclusion: The deposit by debit to the Modvat account was valid compliance with the Tribunal's order, and the Commissioner's application had no merit.

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