Appeal Valid Despite Late 12.5% Tax Deposit; Delay to Be Condoned for Merits-Based Decision by Appellate Authority.

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....Maintainability of appeal - statutory deposit - once an appeal was filed within the limitation period but the deposit of 12.5% of the disputed amount of tax is made beyond the limitation prescribed, the delay in compliance ought to be condoned thereby requiring the appeal to be decided on merits by the appellate authority....