Under the statutory appellate pre-deposit scheme, where the entire underlying tax has been paid, no percentage-based pre-deposit of disputed interest is required. Compliance with applicable pre-deposit conditions results in a deemed stay of recovery of the balance demand while the appeal remains pending. Recovery communications for disputed interest, consequential bank notices, and bank restrictions are therefore barred during that period and must be withdrawn. The basis and computation of the interest demand remain open for determination in the pending appellate proceedings.
Under the statutory appellate pre-deposit scheme, where the entire underlying tax has been paid, no percentage-based pre-deposit of disputed interest is required. Compliance with applicable pre-deposit conditions results in a deemed stay of recovery of the balance demand while the appeal remains pending. Recovery communications for disputed interest, consequential bank notices, and bank restrictions are therefore barred during that period and must be withdrawn. The basis and computation of the interest demand remain open for determination in the pending appellate proceedings.
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