Quasi-judicial tax determination under section 21 is revisable, so the Board of Revenue had jurisdiction to hear the revision.

The Commissioner's determination under section 21 of the Bihar Sales Tax Act, 1947 is quasi-judicial because it resolves disputed questions affecting tax liability or quantum, not merely advisory matters. That order therefore falls within section 24(5) and can be revised by the Board of Revenue. The reasoning was reinforced by section 22, which treats proceedings before the Commissioner as judicial proceedings for specified purposes. The Board of Revenue accordingly had jurisdiction to entertain the revision against the Commissioner's order.

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Issues: Whether the Board of Revenue had jurisdiction to entertain a revision against the Commissioner's order passed under section 21 of the Bihar Sales Tax Act, 1947.

Analysis: The Commissioner's power under section 21 is to determine disputed questions arising between the assessee and the Sales Tax Department, and such determination directly affects liability or the quantum of tax. That function is not merely advisory or consultative but is quasi-judicial in character. A formal determination under section 21 is therefore an order within the scope of section 24(5), making it revisable by the Board of Revenue. Support was also drawn from section 22, which confers powers akin to those of a court and treats proceedings before the Commissioner as judicial proceedings for specified purposes.

Conclusion: The Board of Revenue had jurisdiction to entertain the revision against the Commissioner's order under section 21, and the answer was in favour of the petitioner and against the State.

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