Tax tribunal jurisdiction cannot enforce administrative waiver instructions beyond the statutory scheme.

Under the Madras General Sales Tax Act, the appellate Tribunal's power was confined to orders and reliefs available within the statutory scheme. A Government order waiving collection of additional tax was only an administrative instruction and did not change the dealer's underlying liability under the Act. Because collection matters governed by non-statutory directions lay outside appellate control, the Tribunal could not compel assessing authorities to comply with the executive instruction. The stated principle is that a taxing-statute tribunal can exercise only the powers the statute confers and cannot administer or enforce merely administrative directions.

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Issues: Whether the Appellate Tribunal, while dealing with an assessment appeal or revision under the Madras General Sales Tax Act, could enforce compliance with an administrative Government order waiving collection of additional tax.

Analysis: The statutory appellate power under section 36 was confined to orders made under the Act and to reliefs that could be granted within the statutory scheme. The Government order was only an administrative instruction dealing with enforcement of collection and did not alter the dealer's liability under the Act. Matters of collection governed by non-statutory directions were outside the Tribunal's appellate control, and the Tribunal could not compel assessing authorities to act in conformity with such executive instructions.

Conclusion: The Tribunal had no power or jurisdiction to enforce the administrative Government order, and the refusal to grant relief on that basis was correct.

Ratio Decidendi: An appellate tribunal constituted under a taxing statute can exercise only the powers conferred by that statute and cannot extend its jurisdiction to enforce or administer merely administrative or non-statutory instructions.

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