https://www.taxtmi.com/caselaws?id=796212 The substituted proviso to Section 107(6) of the CGST Act, effective from 1 October 2025, does not require a ten per cent pre-deposit for appeals arising from penalty-only proceedings initiated by show-cause notice before that date. The right of appeal vests when the lis commences and includes the applicable appellate conditions. As the amendment imposes a new, burdensome filing condition without express or necessarily implied retrospective application, pre-commencement proceedings remain governed by the earlier appellate regime and require no such deposit. en-us Fri, 31 Jul 2026 00:00:00 +0530 Sat, 01 Aug 2026 08:34:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796212 The substituted proviso to Section 107(6) of the CGST Act, effective from 1 October 2025, does not require a ten per cent pre-deposit for appeals arising from penalty-only proceedings initiated by show-cause notice before that date. The right of appeal vests when the lis commences and includes the applicable appellate conditions. As the amendment imposes a new, burdensome filing condition without express or necessarily implied retrospective application, pre-commencement proceedings remain governed by the earlier appellate regime and require no such deposit. Case-Laws GST Fri, 31 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796212