Pre-deposit of 12.5% for appeal may not apply when no tax amount is quantified in the dispute.

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....Requirement to comply with the pre-deposit of 12.5 per cent of the disputed tax along with the appeal - Here the appeal does not relate to imposing of tax for the relevant tax period or towards any tax liability or penalty imposed, but for a different purpose where no tax is quantified. Therefore, insisting on payment of 12.5 per cent. of difference of tax may not be proper. - HC....