Binding remand directions control later Tribunal proceedings; a successor Bench cannot ignore them as unnecessary.

A remand order passed by a competent appellate authority with specific directions binds the subordinate forum and the Tribunal itself when the matter returns after remand. A successor Bench cannot disregard those directions on the view that the directed report is unnecessary; the proper inquiry is whether the remand conditions have been complied with. Here, because the report had not been obtained or shown to be on record, the Tribunal erred in deciding the appeals without first securing compliance with the remand order. The text also notes that such appellate orders were treated as final under section 21(9) of the Andhra Pradesh General Sales Tax Act, subject to section 22.

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Issues: Whether a successor Bench of the Sales Tax Appellate Tribunal could ignore the directions contained in an earlier remand order and dispose of the appeals on the ground that the report called for was unnecessary.

Analysis: A remand by a competent appellate forum with specific directions is binding and must be obeyed by the lower authority and by the Tribunal itself when the matter returns after remand. The individual view of a later Bench that the directed report would serve no useful purpose could not override the earlier order. The question was not whether the report was necessary in the later Bench's opinion, but whether the remand directions had been complied with. As the directions were not complied with, the Tribunal erred in proceeding to decide the appeals without securing the report. Section 21(9) of the Andhra Pradesh General Sales Tax Act also treated such appellate orders as final, subject to section 22.

Conclusion: The Tribunal could not disregard the earlier remand directions and was bound to rehear the appeals after obtaining the report or ensuring that it was already on record.

Ratio Decidendi: A remand order passed by a competent appellate authority with directions is binding on the subordinate authority and on the Tribunal in later proceedings, and cannot be ignored on the ground that the successor Bench considers the direction unnecessary.

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