Tribunal jurisdiction and interim stay powers are confined to statute; revisional orders under sales tax law could not sustain stay relief.

The Sales Tax Appellate Tribunal lacked jurisdiction to entertain an appeal against the Joint Commissioner's revisional order under section 19(2-B) of the A.P. General Sales Tax Act and could not grant interim stay of tax recovery. The statutory scheme of sections 19 and 21 vests the power to stay disputed tax collection in the Joint Commissioner, while section 21(1)(a) applies only to orders passed on appeal under section 19. Section 21(6-A) further limits stay relief in specified matters. Because the Tribunal's appellate power is purely statutory and no incidental or inherent jurisdiction can enlarge it, the appeal was incompetent and the interim stay could not stand.

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Issues: Whether the Sales Tax Appellate Tribunal had jurisdiction to entertain an appeal against the Joint Commissioner's order passed in revision under section 19(2-B) of the A.P. General Sales Tax Act and to grant interim stay of recovery of tax.

Analysis: The scheme of sections 19 and 21 of the A.P. General Sales Tax Act shows that the power to stay collection of disputed tax, where available, is specifically vested in the Joint Commissioner and not in the Tribunal. An order passed by the Joint Commissioner in exercise of revisional power under section 19(2-B) is not an order passed on appeal under section 19 within the meaning of section 21(1)(a). Section 21(6-A) further restricts stay of payment in the specified classes of matters. The Tribunal's appellate power being statutory and confined to the provisions conferring it, no incidental or inherent power can be invoked to create a stay jurisdiction that the statute withholds. The appeal before the Tribunal was therefore not competent, and the interim stay could not be sustained.

Conclusion: The Tribunal had no jurisdiction to grant the impugned interim stay, and the assessee's challenge to the Tribunal's order succeeded.

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