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The High Court held that Section 249(4)(a) does not mandate payment of admitted tax before filing an appeal, contrary to the Revenue's contention. The ITAT merely interpreted Section 249(4)(a) regarding entertaining appeals where the amount is deposited before or after filing, without adjudicating merits. As the ITAT order was not erroneous and remanded the matter for adjudication on merits based on precedents, the High Court found no merit in the Revenue's appeal.
The High Court held that Section 249(4)(a) does not mandate payment of admitted tax before filing an appeal, contrary to the Revenue's contention. The ITAT merely interpreted Section 249(4)(a) regarding entertaining appeals where the amount is deposited before or after filing, without adjudicating merits. As the ITAT order was not erroneous and remanded the matter for adjudication on merits based on precedents, the High Court found no merit in the Revenue's appeal.
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