1996 (4) TMI 471

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....furnish a bank guarantee pending appeal is a condition for stay. Admittedly, the petitioner herein furnished a bank gurantee issued by Hong Kong Bank, Bangalore, situated outside the territory of Tamil Nadu. The said Bank guarantee was not accepted. by the respondent on the ground that the guaranatee issued by a bank situated outside Tamil Nadu is not acceptable under rule 24(15-A) Admittedly, the....

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....ld apply for security, then the stand taken by the respondent may be correct. But, the proper rule that should be applied in only rule 31 which reads as follows: "Where it is provided in the Act that an appellant (or an applicant in review proceedings shall furnish security in regard to the payment of tax or loss fee or other amount, the appellant (or applicant) or any person on his behalf shall ....