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    <description>A later pre-deposit amendment requiring payment of 20% of disputed tax before admission of appeal was held inapplicable where the assessment proceeding had already commenced on issuance of notice before the amendment took effect. The right of appeal was treated as a vested substantive right that accrues when the lis begins, and could not be curtailed by a subsequent procedural condition absent express retrospective language or necessary implication. On those facts, rejection of the appeal for non-deposit was unjustified, the order was set aside, and the appeal was directed to be admitted and heard on merits.</description>
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      <description>A later pre-deposit amendment requiring payment of 20% of disputed tax before admission of appeal was held inapplicable where the assessment proceeding had already commenced on issuance of notice before the amendment took effect. The right of appeal was treated as a vested substantive right that accrues when the lis begins, and could not be curtailed by a subsequent procedural condition absent express retrospective language or necessary implication. On those facts, rejection of the appeal for non-deposit was unjustified, the order was set aside, and the appeal was directed to be admitted and heard on merits.</description>
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