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Issues: Whether an appeal lay under section 14 of the Rajasthan Sales Tax Act, 1954 against the order of the Deputy Commissioner (Administration), and whether the Rajasthan Tax Board could entertain such appeal.
Analysis: Section 14(1) confined appeals to the Tribunal to orders passed by the Commissioner under section 12-A or section 15-A, or to orders of an appellate authority disposing of appeals against specified categories of orders. The Deputy Commissioner (Administration) was not an appellate authority within section 2(a), and his order dated 7 November 1986 was neither an order under section 12-A nor under section 15-A. The notification governing exemption certificates empowered the Commercial Taxes Officer to grant the certificate with previous approval of the Deputy Commissioner (Administration); it did not authorise the Deputy Commissioner (Administration) to decide the matter in the first instance.
Conclusion: No appeal lay against the Deputy Commissioner (Administration)'s order, and the Rajasthan Tax Board lacked jurisdiction to entertain the appeal. The revision was therefore allowed and the Board's order was set aside.
Ratio Decidendi: Where a statute expressly limits appellate jurisdiction to specified orders and authorities, an appeal cannot be entertained against an order passed by an authority not covered by that provision.