No assessment made and no order passed under this Act or the rules made thereunder shall be called into question in any Civil Court.

Appeals 2[(20.

1. (1) An appeal from every original order passed under this Act or the rules made thereunder shall lie,-
   • (a) if the order is made by an Assessing Authority, to the Deputy Excise and Taxation Commissioner ;
   • (b) if the order is made by the Deputy Excise and Taxation Commissioner, to the Commissioner ;
   • (c) if the order is made by the Commissioner or any officer exercising the powers of the Commissioner, to a Tribunal.
2. (2) An order passed in appeal by a Deputy Excise and Taxation Commissioner or the Commissioner or any officer on whom the powers of the Commissioner are conferred shall be further appealable to a Tribunal.
3. (3) Every order of a Tribunal and subject only to such order, the order of the Commissioner or any officer exercising the powers of the Commissioner, or the order of the Deputy Excise and Taxation Commissioner or of the assessing authority if it was not challenged in appeal or revision shall be final.
4. (4) No appeal shall be entertained unless it is filed within sixty days from the date of communication of the order appealed against, or such longer period as the appellate authority may allow, for reasons to be recorded in writing.
5. (5) No appeal shall be entertained by an appellate authority unless such appeal is accompanied by satisfactory proof of the payment of the tax or of the penalty, if any, imposed or of both as the case may be : Provided that if such authority is satisfied that the dealer is unable to pay the tax assessed or the penalty, if any, imposed or both, he may, for reasons to be recorded in writing, entertain an appeal without the tax or penalty or both having been paid or after part payment of such tax or penalty or both.
6. (6) Subject to such rules of procedure as may be prescribed, an appellate authority may pass such order on appeal as it deems to be just and proper.]