Amounts paid and collected under protest during the period of...

Amounts paid and collected under protest during the period of disputed tax liability were treated as part of compliance with the statutory pre-deposit requirement, because there was no express provision excluding such deposits from consideration. The High Court noted, prima facie, that the taxpayer had already paid TCS under protest from 1 April 2021, and that those sums related to the disputed liability period but had not been included in the quantification. Rejecting the contention that the payments amounted to an admission of liability for the later period, the Court modified the earlier interim condition and held that no further 10% deposit was required for the petition to proceed on merits.

---