Conditional pre-deposit enables fresh adjudication after non-participation and expiry of appellate limitation, subject to a timely reply.

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....Fresh adjudication was permitted where the petitioner had not participated in the original proceedings and the statutory appellate limitation had expired. The impugned order was quashed, subject to an additional pre-deposit of 25% of the disputed tax and submission of a reply to the show-cause notice within the stipulated period. The earlier order was to operate as an addendum to the show-cause notice for the fresh proceedings. No further extension or concession was available; failure to comply allowed recovery proceedings to continue in accordance with law after due notice.....