Pre-deposit compliance is mandatory where repeated default and delay justify dismissal to protect Revenue interests.

Repeated non-compliance with pre-deposit directions can justify dismissal of an appeal where the appellant has been given adequate opportunity but still fails to deposit the required amount or furnish the directed bank guarantee. The text emphasises that the right of appeal is conditional on compliance with statutory pre-deposit requirements and that the Tribunal may refuse further indulgence when continued default would prejudice the Revenue and amount to abuse of process. The stated result is dismissal of the appeals for failure to comply with the Tribunal's directions and for conduct adverse to the Revenue.

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Issues: Whether the appeals were liable to be dismissed for non-compliance with the pre-deposit directions and failure to protect the Revenue's interest.

Analysis: The Tribunal recorded that repeated opportunities had been granted to comply with the pre-deposit orders, including an extension after the modification application, but the appellants failed to place proof of deposit or furnish the bank guarantee directed by the Tribunal. In view of the continued non-compliance, the Tribunal held that the appellants had aken dilatory tactics and abused the process of law, and that any further indulgence would prejudice the Revenue. Reliance was placed on the principle that the right of appeal is subject to compliance with the statutory pre-deposit requirement and that Revenue protection must be given due weight.

Conclusion: The appeals were dismissed for failure to comply with the pre-deposit directions and for conduct prejudicial to the Revenue.

Ratio Decidendi: Where an appellant repeatedly fails to comply with pre-deposit directions despite adequate opportunity, the appeal may be dismissed to protect the Revenue and prevent abuse of process.

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