Pre-deposit requirement asymmetry exposes penalty-only appeals to uncapped liability, and portal inconsistencies demand statutory correction.
The amended pre-deposit regime creates three classes of GST appeals: (a) disputed tax demand appeals requiring 100% of admitted liability and ten per cent of disputed tax subject to caps; (b) penalty-only appeals requiring ten per cent of the penalty but capped only under the integrated enactment while remaining uncapped under other enactments; and (c) interest/fine-only appeals attracting no pre-deposit. The resulting inter-enactment asymmetry and per-level aggregation can produce disproportionate cumulative deposits and raises interpretive and portal-implementation inconsistencies that warrant legislative correction or administrative clarification. (AI Summary)