Statutory review jurisdiction cannot extend beyond the orders expressly covered by the Finance Act, 1994.

The amended review power under Section 86(2) of the Finance Act, 1994 extended only to orders passed under Sections 73 or 83A. After the 19.8.2009 omission of Section 84 from that provision, the Committee of Chief Commissioners lacked jurisdiction to review an order made under Section 84. A review made beyond the statute was without authority in law, and any departmental appeal founded on such review was not maintainable. The governing principle is that once the legislature excludes a category of orders from a statutory review provision, the reviewing authority cannot exercise jurisdiction over that category.

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Issues: Whether the Committee of Chief Commissioners had the power under Section 86(2) of the Finance Act, 1994, as amended with effect from 19.8.2009, to review an order passed by the Commissioner under Section 84 of the Finance Act, 1994.

Analysis: The review power under Section 86(2) extended only to orders passed under Section 73 or Section 83A of the Finance Act, 1994. After the amendment omitting reference to Section 84 with effect from 19.8.2009, an order passed under Section 84 fell outside the scope of the Committee's review jurisdiction. The impugned order of review was therefore without authority in law, and the appeal filed pursuant to that review could not be maintained.

Conclusion: The review order and the departmental appeal were invalid and the challenge was rejected.

Final Conclusion: The Department's appeal failed at the threshold on the ground of lack of review jurisdiction and was dismissed without examination of the merits.

Ratio Decidendi: Where the legislature omits a category of orders from the statutory review provision, the reviewing authority cannot exercise jurisdiction over that category of orders.

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