Pre-deposit conditions for statutory appeals may be relaxed where the principal amount is already deposited and further insistence is unnecessary.

The Tribunal's insistence on further pre-deposit as a condition for hearing statutory appeals was found unnecessary where the principal sum had already been deposited under an interim order. In view of the totality of the facts and circumstances, the pre-deposit requirement was modified so that the appeals would be heard on merits without any additional deposit. The ruling reflects that pre-deposit directions should be assessed pragmatically and not imposed beyond what is necessary to secure the appeal.

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Issues: Whether the Tribunal's direction to deposit Rs. 1.25 crores with proportionate interest as a pre-condition for hearing the appeal warranted interference.

Analysis: The appeals concerned only the quantum of pre-deposit required for the assessee's statutory appeals. Taking into account the totality of the facts and circumstances, and the fact that the principal amount of Rs. 1.25 crores had already been deposited pursuant to the interim order, further insistence on deposit was found unnecessary.

Conclusion: The pre-deposit direction was modified by directing the Tribunal to hear the appeals on merits without insisting on any further deposit.

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