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Issues: Whether pre-deposit of the disputed duty and penalty was required to be waived pending appeal.
Analysis: The appellant had already deposited more than half of the differential duty demanded. The appellant also relied on financial difficulty shown in the income tax returns. On these considerations, further pre-deposit was dispensed with and protection was granted against coercive recovery steps during the pendency of the appeal.
Outcome: The application for stay was allowed and further pre-deposit was waived.