Inherent stay powers in tax revision proceedings may be exercised to protect effective revisional jurisdiction under the statute.

Section 16D of the Tamil Nadu General Sales Tax Act, 1959 is described as conferring wide revisional power on the Special Committee to examine assessment orders, set them aside, and direct fresh assessment. The commentary states that an adjudicatory statutory authority may regulate its own procedure and pass incidental orders necessary to make its substantive jurisdiction effective, so the absence of an express interim-relief provision does not by itself exclude stay powers. Any such interlocutory relief must still be exercised within the statute and for proper reasons, including during pendency of revision.

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Issues: Whether the Special Committee constituted under section 16D of the Tamil Nadu General Sales Tax Act, 1959 has inherent jurisdiction to pass interlocutory orders, including stay of recovery, during the pendency of a revision.

Analysis: Section 16D confers wide revisional powers on the Special Committee to examine assessment orders and, if necessary, set them aside and direct fresh assessment. A statutory authority entrusted with adjudicatory powers is not powerless to regulate its own procedure or to pass incidental orders necessary to make the substantive jurisdiction effective. The absence of an express provision for interim relief does not exclude such power where it is necessary to do justice and to preserve the efficacy of the revisional process. However, such power must be exercised within the statute and for proper reasons.

Conclusion: The Special Committee has inherent power to entertain and decide an application for stay or other appropriate interlocutory relief during pendency of the revision.

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