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Issues: Whether the appellate authority could refuse to consider the assessee's stay applications on the ground that a security bond had not been furnished before the assessing officer.
Analysis: Section 31 and rule 31(2) did not impose any condition precedent requiring the assessee to furnish a security bond before moving the appellate authority for stay. In the absence of any statutory power authorising such a precondition, the refusal to entertain the stay applications could not be sustained.
Conclusion: The rejection of the stay applications on the ground of furnishing a security bond was unsustainable and was set aside; the appellate authority was directed to consider the stay applications on merits and in accordance with law.
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