Finality of appellate orders defeats a later challenge where no legal infirmity or jurisdictional error is shown.

A challenge to an appellate order was found not maintainable after the order had attained finality, because no appeal had been filed against it and the explanation for not pursuing the further remedy was rejected. The petition was also misdirected, as it attacked the original appellate order rather than the later refusal to rectify under the Tamil Nadu General Sales Tax Act. On the merits, the assessment formula adopted by the assessing authority had already been examined and upheld as lawful, and no legal infirmity or jurisdictional error was shown to justify interference. The challenge was dismissed.

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Issues: Whether the original petition challenging the appellate order was maintainable after the order had attained finality, and whether any illegality was shown in the assessment formula adopted by the assessing authority and upheld in rectification proceedings.

Analysis: The petition was directed against the original appellate order and not against the later refusal to rectify under section 55 of the Tamil Nadu General Sales Tax Act, 1959. No appeal had been filed against the original appellate order, and the explanation for not pursuing the further remedy was rejected. The Tribunal also noted that the Appellate Assistant Commissioner had examined the facts and the formula adopted by the assessing authority and had held that the formula was within the law. No legal infirmity or jurisdictional error was shown to warrant interference.

Conclusion: The challenge failed, the original appellate order was treated as final, and the original petition was dismissed.

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