Revisional proceedings during a pending appeal can justify full waiver of pre-deposit where statutory restriction is breached.

Revisional proceedings initiated while an appeal on the same issue was pending were treated as contrary to the statutory restriction in Section 84(4) of the Finance Act, 1994. On that basis, the appellants were found to have a prima facie case for interim relief, and pre-deposit was waived in full against the demand in the impugned order.

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Issues: Whether the appellants were entitled to waiver of pre-deposit in a matter where revisional proceedings were initiated while an appeal on the same issue was pending before the appellate authority.

Analysis: The revisional power was exercised during the pendency of the appeal, which was treated as contrary to the statutory restriction contained in Section 84(4) of the Finance Act, 1994. On that basis, the appellants were found to have a prima facie case for interim relief.

Outcome: Waiver of pre-deposit of the entire amount demanded in the impugned order was granted.

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