(4)No appeal against an order of assessment with or without penalty or against an order imposing penalty shall ordinarily be entertained by an appellate authority, unless such appeal is accompanied by satisfactory proof of payment of the tax with or without penalty or, as the case may be, of the payment of the penalty in respect of which an appeal has been preferred:Provided that an appellate authority may, if it thinks fit, for reasons to be recorded in writing, entertain an appeal against such order-(a)without payment of tax with penalty (if any) or as the case may be, of the penalty, or(b)on proof of payment of such smaller sum as it may consider reasonable, or(c)on the appellant furnishing in the prescribed manner security for such amount as the appellate authority may direct.
