Section 73(4) in The Gujarat Value Added Tax Act, 2003
(4)No appeal against an order of assessment shall ordinarily be entertained by an appellate authority, unless such appeal is accompanied by satisfactory proof of payment of the tax 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 if may consider reasonable, or(c)on the appellant furnishing in the prescribed manner, security for such amount as the appellate authority may direct.]