Vested appeal rights prevent retrospective pre-deposit requirements in penalty-only appeals arising from pre-amendment show-cause notices.

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....The vested right of appeal arises when the lis is instituted, and a later amendment imposing a fresh pre-deposit obligation does not apply to pending proceedings without clear legislative intent. Where a penalty-only appeal arose from a show-cause notice issued before the amended proviso took effect, the post-amendment pre-deposit requirement could not be imposed. The Registry's objection was set aside, the appeal was admitted without pre-deposit, and jurisdictional and merits issues remained open for final hearing.....