Preliminary jurisdiction and limitation objections must be decided first when they raise pure questions of law and affect maintainability.

Where preliminary objections raise pure questions of law affecting jurisdiction or limitation and can be decided without evidence, the authority must determine them at the threshold before proceeding further. If those objections are accepted, the proceedings may end or further inquiry may become unnecessary. An authority cannot defer decision on such objections after hearing the parties without giving reasons. The Commissioner was therefore required to decide the revision-related preliminary objections first, and the petitioner was entitled to a direction requiring expeditious determination of those objections.

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Issues: Whether the Sales Tax Commissioner was required to decide the preliminary objections relating to jurisdiction and limitation before proceeding further with the revision notices.

Analysis: The objections raised were questions of law going to the root of the matter and were capable of being decided without evidence. Where such preliminary questions arise, the authority dealing with the matter must determine them first, because a negative answer may end the proceedings or render a further enquiry unnecessary. After hearing full arguments on those objections, the Commissioner could not refuse to decide them and defer consideration without giving reasons.

Conclusion: The Commissioner was bound to decide the preliminary objections first, and the petitioner was entitled to a direction requiring such decision with expedition.

Ratio Decidendi: When preliminary objections raise pure questions of law affecting jurisdiction or the maintainability of proceedings and can be decided without evidence, the authority must decide them at the threshold before entering upon the merits.

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