Revisional jurisdiction limits: Financial Commissioner could not revise a Commissioner's original order under the sales tax ordinance.

The Commissioner's determination under section 18 was an exercise of original jurisdiction over first-instance disputes, including dealer status. Revisional power under section 21(3) extended only to matters decided under the preceding revisional provision in section 21(1), not to orders made under section 18. The Financial Commissioner therefore lacked statutory authority to revise the Commissioner's original order, and the refusal to entertain the revision was consistent with the Ordinance; the challenge failed.

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Issues: Whether a revision lay to the Financial Commissioner against an order passed by the Commissioner in the exercise of original jurisdiction under section 18 of the Pepsu General Sales Tax Ordinance, 2006.

Analysis: Section 18 empowered the Commissioner to decide, in the first instance, disputes including whether a person was a dealer, and that power was treated as original jurisdiction. Section 21(3) conferred revisional power on the Financial Commissioner only in respect of cases decided under the preceding revisional provision, namely section 21(1). As the Commissioner's order in the present matter was not made in revision but under section 18, the Financial Commissioner had no statutory power to revise it. The refusal to entertain the revision was therefore consistent with the scheme of the Ordinance and did not involve failure to exercise jurisdiction.

Conclusion: The revision before the Financial Commissioner was not maintainable, and the challenge to that refusal failed.

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