Remand for fresh enquiry upheld where liability turned on unresolved facts and no revisional error of law was shown.

Where liability depends on unresolved factual inquiry, remand for fresh enquiry was justified because the real nature of the transactions and identification of the last purchaser had not yet been established. In revision under section 22, no interference was warranted because no material showed that the Tribunal had erroneously decided, or failed to decide, any question of law within its revisional jurisdiction. The remand order therefore stood, and the revision failed.

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Issues: Whether interference was warranted with the Tribunal's order remanding the matter for fresh enquiry and whether any question of law arose under section 22 of the Act.

Analysis: The appellate authorities had found that the real nature of the transactions required further investigation before liability could be determined. The Tribunal held that the goods, whichever schedule entry they fell under, were taxable at the point of last purchase in the State, but that the factual inquiry necessary to identify the last purchaser had not been completed. In revision, no material was shown to establish that the Tribunal had decided any question of law erroneously or omitted to decide a question of law within the scope of section 22 of the Act.

Conclusion: No interference was called for with the remand order, and the revision failed.

Ratio Decidendi: Where liability depends on unresolved factual inquiry, and no error in deciding or omitting a question of law is shown within the revisional jurisdiction, interference with a remand order is unwarranted.

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