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Issues: Whether the appellant was entitled to waiver of pre-deposit and stay of recovery in respect of the duty demanded on amounts collected from dealers for printing their particulars on free diaries.
Analysis: The appellant's activity of distributing diaries and separately charging dealers for printing their particulars in the diaries was treated as distinct from the manufacture and sale of electric fans. On that basis, the demand was found to raise a prima facie issue warranting interim protection.
Outcome: Pre-deposit was waived and recovery of the disputed demand was stayed until disposal of the appeals.