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Issues: Whether the petitioner could be relegated to the statutory appellate remedy despite failure to file the appeal within limitation.
Analysis: The challenged demand order was appealable under the statutory appellate mechanism. Although the petitioner had not pursued that remedy within the prescribed period, permission was granted to institute an appeal upon a stipulated deposit, with the appellate authority required to consider it on merits rather than reject it as time-barred.
Outcome: The petitioner was permitted to pursue the statutory appeal subject to the stipulated deposit.