Mandatory pre-deposit requirement for tax appeals; deposit condition affects appeal admissibility and refund with interest following success. Substituted appeal provisions impose a mandatory pre-deposit obligation for disputes over duty or penalty, applicable to appeals filed after enactment; deposits are calculated on the amount in the order being appealed (including Commissioner (Appeal) amounts when appealing to the Tribunal), aggregate penalties are treated collectively, and short or non payment risks appeal rejection. Payments made during investigation may be credited toward the pre deposit when an appeal is filed, subject to limits; excess payments are not treated as pre deposits. Successful appellants are entitled to refund of pre deposits with prescribed interest, and recovery beyond the deposited amount is restrained during pendency if proof of deposit and appeal memo are produced.