( 1 ) THE High Court had by the impugned judgment struck down the provisos to Section 20 (1) and Section 21 (2) of the Tripura Sales Tax Act which had provided that no appealrevision against an order would be entertained by the prescribed authority/commissioner unless the amount of tax assessed or the penalty levied is paid, discretion being given to the authority for permitting payment of not less than 50 per cent of the tax assessed or the penalty levied.

( 2 ) THE aforesaid Sections 20 (1) and 21 (2) along with the relevant provisos read as follows:"20. Appeal. (1) Any dealer objecting an order of assessment or penalty passed under this Act, may, within thirty days from the date of the service of such order, appeal to the prescribed authority against such assessment or penalty: provided that no appeal shall be entertained by the said authority unless he is satisfied that the amount of lax assessed or the penalty levied has been paid: provided further that the authority before whom an appeal has been filed may, for reasons to be recorded in writing, direct the appellant to pay any lesser amount which shall not be less than fifty per cent of the tax assessed or fifty per cent of t