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Issues involved: Granting opportunity of hearing, deposit requirement, remand to Commissioner (Appeals).
The judgment directs the appellant to deposit Rs. 3 lakh by a specified date and produce a copy of the challan before the Commissioner (Appeals) with an application to fix a date of hearing on merit. The Commissioner (Appeals) is instructed to grant an opportunity of hearing to the appellant on merits, contingent upon verifying the deposit particulars. The stay application is disposed of, with the matter remanded to the Commissioner (Appeals) to carry out the aforementioned direction, subject to verifying the challan.
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