(1) When appealing against the decision of the Commission, the amount of tax determined in case of tax determination and the amount of fine in case of penalty, and in case of both, the amount of fine and both amounts shall not be appealed without depositing the bond in the office designated by the Commission.

(2) If the Commission deems it appropriate, half of the amount of tax to be deposited in accordance with sub-section (1) may be deposited in cash, and in the case of half, it may be taken as bailment or bailment. If the sold goods are perishable or if their quality deteriorates and the value decreases, according to the prevailing Nepalese law, the value of the auctioned goods should be kept as a bond in accordance with the tax related matters. In the case of vehicles or machinery, the property can be handed over by taking a surety bond or Mathwar Dhan Jamani.