Pre-deposit requirement under Punjab VAT law upheld where no factual basis showed entitlement to further relaxation.

Interference with a dismissal for non-compliance with the pre-deposit condition under the Punjab Value Added Tax Act was refused because the appellant neither deposited the required amount nor showed insolvency, lack of funds, or any other factual basis for further relaxation. The appellate authorities had already reduced the pre-deposit from 25% to 10% as a matter of discretion, and no illegality or perversity was demonstrated in that exercise. As no substantial question of law arose, the High Court declined to disturb the order sustaining dismissal for non-deposit.

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Issues: Whether the appellant was entitled to interference with the dismissal of its appeal for non-compliance with the pre-deposit requirement under Section 62(5) of the Punjab Value Added Tax Act, 2005.

Analysis: The appeal under Section 68 of the Punjab Value Added Tax Act, 2005 challenged the orders of the appellate authorities which had required deposit of 10% of the tax demand as a pre-condition for hearing the merits. The appellant did not deposit the amount, nor did it establish insolvency, absence of funds, or any other factual basis to justify further relaxation. The authorities below had already reduced the pre-deposit requirement from 25% to 10% on a sympathetic assessment of the matter, and no illegality or perversity was shown in that exercise of discretion. In the absence of a substantial question of law, the High Court declined to interfere.

Conclusion: The challenge to the dismissal for non-deposit failed, and the order against the appellant was sustained.

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