Section 20. Appeal to the appellate authority

(1) Subject to other provisions of this Act, an appeal against any order of the prescribed authority, shall lie to the appellate authority. (2) No appeal shall be entertained after the expiry of sixty days from the date of receipt of demand notice or receipt of the order : Provided that, the appellate authority may admit the appeal after the expiry' of the above period, if he is satisfied that there was sufficient cause for the delay. (3) No appeal against an order of assessment with or without penalty or interest or against an order imposing penalty or interest shall be entertained by an appellate authority, unless such appeal is accompanied by satisfactory proof of the payment of forty per cent of tax with or without penalty or interest or as the case may be of the payment of penalty or interest in respect of which appeal has been preferred. (4) The appellate authority in disposing of an appeal, may - (i) confirm, annul, reduce, enhance, or otherwise modify the assessment or penalty or interest, or (ii) set aside the assessment or penalty or interest and direct the authority which made the assessment or imposed the penalty or charged the interest to pass a fresh order after further inquiry on specified points. (5) No order under this section shall be passed without giving the appellant or his representative, and, where the appellate authority is the Board, without giving the authority whose order or direction is the subject of the appeal or his representative, a reasonable opportunity of being heard.