The Revenue argued that the amended pre-deposit requirement was procedural and applicable to appeals filed after October 1, 2025. They also emphasized a severe financial hardship would be caused by the pre-deposit requirement. On the other side, the Revenue argued that the pre-deposit requirement was a procedural condition rather than a substantive right. The Department emphasized that post amendment pre-deposit was mandatory and left no room for waiver. Allowing taxpayers to bypass the pre-deposit requirement, the Revenue argued, would undermine legislative intent, completely.