Conditional release of detained goods allowed pending revision, subject to payment and affidavit undertaking compliance with the final order.

Pending revisional proceedings initiated by notice under Section 108, conditional release of detained goods was permitted on payment of the specified amount and filing of an affidavit undertaking compliance with the final revisional order. The Court noted that no final revisional order had yet been passed, and left the petitioner's jurisdictional and other objections open to be raised before the Revisional Authority. Because the appellate order had already resulted in a quantified demand and the goods remained under restraint, the arrangement was framed to secure revenue while preserving the revisional process. The relief was therefore limited and expressly subject to the outcome of revision.

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Issues: Whether, pending revision proceedings initiated against the appellate order, the petitioner was entitled to release of the detained goods on furnishing payment and an affidavit undertaking compliance with the final revisional order.

Analysis: The notice under Section 108 had only initiated revisional proceedings and no final revisional order had been passed. The jurisdictional and other objections raised against the initiation of revision were left open to be urged before the Revisional Authority. As the appellate order had resulted in a quantified demand and the goods were still under restraint, the Court considered it appropriate to secure the revenue by requiring payment of a further sum and an undertaking that the petitioner would abide by the revisional outcome. The relief was fashioned as a conditional arrangement pending the revisional proceedings.

Conclusion: The petitioner was granted limited relief by directing release of the goods on payment of the specified amount and filing of an affidavit, while all other contentions were left open for the revisional proceedings.

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