Pre-deposit requirement under Punjab VAT upheld where appellate authorities found the condition reasonable and no substantial question of law arose.

The appeal mechanism under the Punjab Value Added Tax Act, 2005 required prior deposit of 25% of the additional demand, penalty and interest before an appeal could be entertained, subject to waiver in cases of undue hardship. On the facts, the demand related only to tax, the pre-deposit condition was found reasonable, and the Tribunal had already granted further time for compliance. No perversity in the Tribunal's approach was shown, and the challenge did not raise any substantial question of law.

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Issues: Whether the condition of prior deposit of twenty-five per cent of the additional demand under the Punjab Value Added Tax Act, 2005 was justified and whether the appeals disclosed any substantial question of law.

Analysis: The appeal provision under Section 62(5) required deposit of twenty-five per cent of the additional demand, penalty and interest before an appeal could be entertained, though the first appellate authority could grant waiver in appropriate cases of undue hardship. The demand in the present case was confined to tax, and the condition imposed by the appellate authorities for entertaining the appeal was found to be reasonable. The Tribunal had also granted further time to enable compliance. No perversity in the Tribunal's order was shown, and the challenge did not give rise to any substantial question of law.

Conclusion: The condition of pre-deposit was upheld, and the appeals were held to be without merit.

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