Mandatory Committee approval for Revenue appeals was absent, rendering the appeals not maintainable and barring merits review.

Revenue appeals filed without a recorded opinion of the Committee of Commissioners on the legality and propriety of the impugned order were treated as procedurally defective. The note sheet did not establish the mandatory approval required for institution of the appeals, and the defect was not cured by later miscellaneous applications. As a result, the appeals were found not maintainable and could not be examined on merits; the associated miscellaneous applications were also dismissed in limine.

---

---

Issues: Whether the Revenue appeals were maintainable in the absence of an opinion of the Committee of Commissioners supporting filing of the appeals.

Analysis: The note sheet placed by the Revenue did not show that the Committee of Commissioners had formed the required opinion on the legality and propriety of the impugned order. In the absence of such mandatory approval, the defect in institution of the appeals was not cured by the later miscellaneous applications. The appeals, therefore, could not be entertained on merits.

Conclusion: The Revenue appeals were held to be not maintainable and were dismissed in limine along with the miscellaneous applications.

---