Statutory tribunal jurisdiction ends after final disposal; it cannot order release of seized property amid pending criminal proceedings.

A statutory tribunal cannot revive jurisdiction after finally disposing of a release application and cannot use incidental or contempt powers to interfere with a criminal proceeding or order release of seized goods and vehicles. Where the enabling statute confines jurisdiction to tax matters and expressly excludes proceedings triable by criminal courts, the tribunal becomes functus officio once the main matter ends. Any issue concerning the genuineness of the criminal prosecution and release of property in that context lies with the criminal court seized of the case. The impugned release direction was therefore quashed.

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Issues: Whether the Taxation Tribunal, after finally disposing of the release application and after a criminal case had been set in motion, retained jurisdiction to direct release of the seized goods and vehicles, and whether such direction could be sustained as an exercise of incidental or contempt jurisdiction.

Analysis: The Tribunal is a statutory body and can act only within the limits of its enabling statute. Its jurisdiction under section 6(1) of the West Bengal Taxation Tribunal Act, 1987 extends to matters concerning levy, assessment, collection and enforcement of tax and matters connected therewith or incidental thereto, but section 6(2) expressly excludes proceedings triable by criminal courts under the Code of Criminal Procedure, 1973. Once the original proceeding had been finally disposed of, the Tribunal became functus officio and could not revive jurisdiction by treating an oral mention as an incidental or miscellaneous continuation. The question whether the subsequent criminal prosecution was sham, and any order for release of seized goods or vehicles in that context, lay within the competence of the criminal court seized of the matter under the Code of Criminal Procedure, 1973. The impugned direction was also not sustainable as contempt jurisdiction because it did not satisfy the statutory requirements governing that power.

Conclusion: The Tribunal had no jurisdiction to pass the impugned release order after disposal of the main matter and in the face of the criminal proceedings. The challenge succeeded and the impugned orders were quashed.

Ratio Decidendi: A statutory tribunal cannot, after finally disposing of a matter, exercise incidental or contempt powers to interfere with a criminal proceeding or direct release of property where jurisdiction has been expressly ousted and the matter falls within the criminal court's competence.

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