Supreme Court extension of tax-deposit time binds subordinate authorities and prevents dismissal of appeals as infructuous.

Where the Supreme Court granted further time to deposit tax, subordinate appellate authorities had to treat that direction as extending the payment period and could not dismiss the pending appeals as infructuous. The Tribunal's approach in disregarding the Supreme Court's order and assuming that different directions would have followed had the earlier dismissal been disclosed was found to rest on conjecture rather than law. The dismissal was held arbitrary, unreasonable, unjust, and unsustainable in law, so the appeals were set aside and remanded for fresh hearing in accordance with law.

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Issues: Whether the Sales Tax Tribunal was justified in dismissing the appeals as infructuous despite the Supreme Court having granted further time to deposit the tax amount.

Analysis: The order granting further four weeks to make the deposit was treated as extending the time fixed for payment by the appellate authorities and the Tribunal. The Tribunal could not ignore, directly or indirectly, the Supreme Court's order or proceed on the assumption that the appeals had become infructuous. Its view that the Supreme Court would have issued different directions if apprised of the earlier dismissal of appeals was held to be based on conjecture and imagination rather than law. The dismissal of the appeals was therefore held to be arbitrary, unreasonable, unjust, and unsustainable in law.

Conclusion: The dismissal of the appeals by the Tribunal was set aside and the matter was remanded for fresh hearing in accordance with law.

Ratio Decidendi: When the Supreme Court grants further time to deposit a tax amount, subordinate appellate authorities must treat that order as extending the time for deposit and cannot dismiss the appeal as infructuous by disregarding the Supreme Court's direction.

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