(1.) The first appeal of the revisionist is pending before the Additional Commissioner (Appeals). The revisionist has already been granted interim protection by the tribunal and the realisation of the disputed amount of tax has been stayed provided it furnishes security of the 95% of the disputed amount and deposits the balance 5% of the amount.
(2.) The revisionist by means of this revision wants that balance 5% amount which has been directed to be deposited may also be stayed.
(3.) The revision only for the stay of the realisation of the balance amount and challenging the interlocutory order of partial stay is not maintainable particularly when no question of law is involved and all legal aspects arising are open for adjudication by the appellate authority.