Tax revision maintainability turns on a question of law and strict compliance with mandatory service requirements.

A tax revision may be rejected where it challenges Tribunal findings without disclosing any error of fact or law and no question of law arises for consideration. The High Court Rules may also apply mandatory service requirements to tax revisions, including service on the assessee and filing an affidavit of service within the prescribed time; non-compliance with that procedural obligation can render the revision not maintainable. The governing principle is that both the absence of a legal issue and failure to comply with mandatory service procedure justify dismissal of the revision.

---

---

Issues: Whether the tax revision was liable to be dismissed for want of a question of law and for non-compliance with the requirement of filing an affidavit of service under the High Court Rules.

Analysis: The revision challenged findings recorded by the Tribunal, but no error of fact or law was shown and no question of law arose for consideration. Independently, the revision was governed by Chapter 27 of the High Court Rules, which, by Rule 20, applied the procedural requirements to revisions under tax enactments. Rule 5(2) required the Commissioner to serve the assessee and file an affidavit of service within the prescribed time, and the record showed that this mandatory requirement had not been complied with for several years after filing.

Conclusion: The revision was not maintainable and was liable to be dismissed.

Ratio Decidendi: A tax revision can be dismissed where it raises no question of law and where mandatory procedural requirements for service and proof of service under the applicable High Court Rules are not complied with.

---