Second appeal lies from summary rejection of a first appeal for procedural non-compliance under the statutory appellate scheme.

An order summarily rejecting a first appeal for defects or procedural non-compliance is treated as a disposal of the appeal, not a mere administrative step. The statutory right of appeal is to be construed liberally and extends to orders ending the appeal on preliminary grounds such as limitation, incompetence, or irregularity. On that basis, a summary rejection confirms the original order and attracts the further appellate remedy, so a second appeal lies to the Tribunal.

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Issues: Whether a second appeal lies to the Sales Tax Tribunal against an order of summary rejection passed by the first appellate authority for non-compliance with the statutory rules.

Analysis: An order summarily rejecting a first appeal for defects or non-compliance with procedural requirements is still an order passed on appeal and amounts to a disposal of the appeal within the meaning of the relevant provision. The statutory right of appeal is to be construed liberally so as to include not only decisions on the merits but also orders disposing of the matter on preliminary grounds such as limitation, incompetence, or irregularity. A summary rejection therefore confirms the original order and attracts the further appellate remedy.

Conclusion: A second appeal lies to the Tribunal against a summary rejection of the first appeal. The question was answered in the affirmative, in favour of the Revenue.

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