Directory time limit in remand order did not divest Tribunal of jurisdiction despite delayed revision disposal.

A remand order giving the Tribunal jurisdiction to rehear a revision was accompanied by a six-month direction for disposal, but that time limit was intended to ensure expedition and was not framed in mandatory or negative terms. Because the order contained no express bar on jurisdiction after expiry of the period, and no indication that delay would nullify the rehearing power, the limit was treated as directory rather than mandatory. The Tribunal therefore retained jurisdiction even though it decided the revision after six months, and the challenge based solely on delay failed.

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Issues: Whether the Tribunal below lost jurisdiction to hear and dispose of the revision because it was decided after expiry of the six-month period fixed in the remand order.

Analysis: The remand order conferred jurisdiction on the Tribunal below to rehear the revision, but the six-month direction was intended to secure expeditious disposal of an old matter. The direction was not framed in negative language and did not contain an express bar on exercise of jurisdiction after the stipulated period. In the absence of such mandatory wording or any indication that non-compliance would frustrate the conferment of jurisdiction, the time-limit was held to be directory rather than mandatory. The delayed disposal, by itself, did not render the later order a nullity or divest the Tribunal of jurisdiction.

Conclusion: The Tribunal below retained jurisdiction despite disposal beyond six months, so the challenge on that ground failed.

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