Express statutory bar on revising seizure orders under VAT law led the Court to refer the issue to a Larger Bench.

Section 60(b) of the U.P. Value Added Tax Act, 2008 was read as expressly barring appeal or revision against an order of seizure of goods, and the Court noted conflicting views on whether the validity of such seizure could still be examined under the Act. Because the statutory language was considered plain and the scope of challenge remained disputed, the matter was not finally determined on merits in the revisional order. Instead, it was directed to be placed before the Chief Justice for constitution of a Larger Bench to authoritatively resolve the question.

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Issues: Whether the validity of a seizure order under the U.P. Value Added Tax Act, 2008, or an order passed under section 48(7) of the Act or by the Tribunal under section 57(4) of the Act, can be challenged in revision before the High Court in view of the bar contained in section 60(b) of the Act.

Analysis: The order noted that section 60(b) expressly bars an appeal or revision against an order of seizure of goods. It also noticed earlier conflicting views on whether the validity of the seizure itself could be examined in proceedings under the Act, and observed that the language of the provision is plain and unambiguous. In light of the existing divergence and the importance of the question, the matter was considered fit for authoritative determination by a larger bench.

Conclusion: The question was not finally decided on merits in this order and was directed to be placed before the Chief Justice for constitution of a Larger Bench.

Final Conclusion: The revision did not culminate in a substantive determination of the legality of the seizure order and was referred for consideration by a Larger Bench.

Ratio Decidendi: Where the statute contains an express bar against appeal or revision from an order of seizure, and conflicting views exist on the scope of challenge to such seizure, the issue may be referred for determination by a Larger Bench rather than finally decided in the revisional order.

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