Administrative circulars cannot interpret tribunal orders or affect quasi-judicial adjudication without statutory authority.

The Commissioner of Commercial Taxes could issue administrative instructions for subordinate officers, but not circulars purporting to interpret or clarify orders of courts or tribunals in a manner affecting quasi-judicial adjudication under the Andhra Pradesh General Sales Tax Act, 1957. As the impugned communication was expressly treated as an internal circular and not as an exercise of statutory power under section 42-A, it lacked any lawful source of authority and could not be sustained. The Andhra Pradesh High Court therefore set aside the circular, while leaving the show cause notices undisturbed and permitting the assessing authority to proceed on its own merits and in accordance with law.

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Issues: Whether the Commissioner of Commercial Taxes had authority, dehors section 42-A of the Andhra Pradesh General Sales Tax Act, 1957, to issue a circular clarifying and interpreting the order of the Sales Tax Appellate Tribunal, and whether such circular was liable to be set aside.

Analysis: The Commissioner specifically stated that the impugned communication was only an internal circular issued for subordinate officers and was not issued in exercise of the power under section 42-A. In view of that stand, the Court found it unnecessary to examine the scope of section 42-A or to decide abstract questions on the binding nature of circulars issued under that provision. The Court held that the head of the department may issue administrative instructions for effective administration, but such power does not extend to interpreting orders of courts or tribunals or to issuing circulars in matters that affect quasi-judicial adjudication under the Act. Since the impugned circular was not traceable to any statutory source of power under the Act, it could not stand.

Conclusion: The impugned circular was without authority of law and was set aside. The show cause notices were not quashed, and the assessing authority was left free to proceed on its own merits and in accordance with law.

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