Appellate remedy preserved subject to deposit, with limitation waived if the appeal is filed and security is paid in time.

The writ petition was disposed of by permitting the petitioner to file a statutory appeal within 15 days, provided 25% of the disputed tax is deposited. If the appeal and deposit are made within that period, the appellate authority must entertain the appeal and decide it on merits without raising limitation. The direction preserves the assessee's appellate remedy while making timely deposit a condition for consideration.

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Outcome: The writ petition was disposed of by granting liberty to the petitioner to file an appeal within 15 days, subject to depositing 25% of the disputed tax, and directing the appellate authority to entertain and decide the appeal on merits without reference to limitation if the appeal and deposit were made within time.

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