402. REVIEW BY TRIBAL COURT.

1. Within 30 days after notice of any decisions by the Tax Commission on a petition for redetermination, any taxpayer aggrieved thereby may petition the Rosebud Sioux Tribal Court for review of the decision by the Tax Commission.
2. Upon such review, which shall be by the Court sitting without jury, no new or additional evidence may be introduced, but the matter shall be heard on the record established before the Tax Commission as certified by the Commission.
3. Before making such petition to the Tribal Court, the full amount of taxes, interest, penalties, and any other charges determined to be due by the Tax Commission must be deposited with the Commission or an undertaking filed in such amount and with such sureties and the Commission shall require, sufficient to satisfy any taxes, interest and penalties, and any charges incident to the appeal.
4. The Tribal Court shall uphold all factual findings by the Commission unless the Court determines that such findings are not supported by substantial evidence in the record established before the Tax Commission, the Court shall give proper weight to the Commissions interpretation of this Code and any regulations promulgated thereunder.
5. The determination of the Tribal Court is final, and no further appeal shall be allowed.
6. In no event is the Court authorized to alter tax rates established pursuant to this Code, to enjoin the collection of any taxes pursuant to this Code, or to award or order the payment of damages or to fashion any remedy except to order a refund of the amount of taxes, penalties, interest, or other charges in controversy, plus interest on the refund as provided in Subsection (7) of this Section, unless an additional remedy is specifically provided by this Code.
7. Refunds ordered by the Court shall bear simple interest at the rate of 10% per year from the date of the overpayment to the date of the refund; provided, that no interest shall be paid on a refund when the Court determines that the refund is for an overpayment that resulted from the negligence of the taxpayer.