Separate speaking orders on reopening objections are mandatory; deciding them within reassessment invalidates jurisdiction and precludes revival of st...
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Statutory pre-deposit for a Tribunal appeal must be assessed against the disputed tax remaining after the first appellate authority reduces the tax demand. The deposit made at the first appellate stage represents a prescribed portion of the dispute, not payment of a separate liability. No further pre-deposit under section 112(8) is required where the amount already deposited equals or exceeds the aggregate prescribed percentage of the surviving disputed tax. Requiring an additional deposit in those circumstances would mechanically duplicate the pre-deposit obligation and produce an anomalous, unworkable result.
Statutory pre-deposit for a Tribunal appeal must be assessed against the disputed tax remaining after the first appellate authority reduces the tax demand. The deposit made at the first appellate stage represents a prescribed portion of the dispute, not payment of a separate liability. No further pre-deposit under section 112(8) is required where the amount already deposited equals or exceeds the aggregate prescribed percentage of the surviving disputed tax. Requiring an additional deposit in those circumstances would mechanically duplicate the pre-deposit obligation and produce an anomalous, unworkable result.
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