Right to plead through an authorised agent was excluded by the statutory sales tax procedure.

The procedural scheme under the sales tax Act distinguished between the right to act and the right to plead. While an appeal could be presented by a duly authorised agent, the hearing and argument provisions confined pleading in appeals and revisions to the party, a lawyer, or a registered accountant where expressly permitted. Rule 77B did not expand that limited representation. The statutory restrictions displaced any broader common law right to appear through an agent, so a recognised agent or special power-of-attorney holder had no enforceable right to plead before the appellate or revisional authorities.

---

---

Issues: Whether a dealer or assessee had a right to be represented and to plead through a recognised agent or special power-of-attorney holder before the sales tax appellate and revisional authorities under the Act and the Rules.

Analysis: The procedural scheme distinguished between the right to act and the right to plead. Rule 67 permitted presentation of an appeal by the appellant or a duly authorised agent, and rule 77A likewise dealt with acts which could be done by a lawyer, registered accountant, or recognised agent, but the express language of rules 68 and 69 confined the hearing and argument of appeals and revisions to the party, a lawyer, or a registered accountant, as specifically provided. Rule 77B, being a control provision over representatives, did not enlarge the right of pleading. The common law principle that a litigant may appoint an agent yielded where the statutory scheme, either expressly or by necessary implication, restricted that right. The earlier decision on the same rules remained binding and showed that the statutory provisions cut down any wider claim to representation for pleading.

Conclusion: The assessee had no enforceable right to plead through the petitioner before the sales tax appellate or revisional authorities, and the challenge failed.

---