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After hearing both the counsel we have considered the record of the case including the rival submissions, grounds of appeal, default assessment orders, orders passed by the OHA and the decisions cited this Tribunal is of the considered view that the point raised for consideration can only be meticulously examined on the basis of documents and evidence to be produced when the matter is heard on merits.

Moreover, the provisions of section 76( 4) of the Act cannot be termed as undue hardship or irreparable loss to the appellant. On compliance of the orders the file be listed for hearing on 01. 2017. It is contended by the petitioner that there is no radical difference between the transactions that were the subject matter in the previous ruling and the present case, save and except its customers are different.