No inherent review power for tribunals; post-decisional hearing may continue and remand time may be extended.

A tribunal has no inherent power to review its final order unless review is expressly conferred by statute, and the distinction between review and rectification cannot be used to reopen the merits absent such power. On that basis, the review petition against the earlier remand order was held not maintainable and dismissed. The tribunal also found no legal impediment to the Designated Authority continuing the post-decisional hearing despite the pending review, as the affected parties could still participate and raise their submissions. Because the earlier period had expired, the time for completing the remand directions was extended to secure compliance and preserve hearing rights.

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Issues: (i) Whether the review petition against the Tribunal's earlier remand order was maintainable in the absence of an express statutory power of review; (ii) Whether the Designated Authority could continue the post-decisional hearing and whether the time fixed earlier required extension.

Issue (i): Whether the review petition against the Tribunal's earlier remand order was maintainable in the absence of an express statutory power of review.

Analysis: The Tribunal held that review is not an inherent power and can be exercised only when specifically conferred by statute. It relied on the settled distinction between review and rectification of mistake, and held that the cited authorities did not enlarge its jurisdiction to reopen the final order on merits. The earlier order had already protected the domestic industry by continuing the duty and providing post-decisional hearing, so no prejudice warranting review was shown.

Conclusion: The review petition was not maintainable and was dismissed.

Issue (ii): Whether the Designated Authority could continue the post-decisional hearing and whether the time fixed earlier required extension.

Analysis: The Tribunal found no legal bar to the Designated Authority proceeding with the post-decisional hearing notwithstanding the review petition. It held that the domestic industry and other interested parties could still participate in the hearing, and that the issues raised by them could be urged before the Authority. Since the earlier period had expired, the Tribunal extended the time to enable compliance with the remand directions.

Conclusion: The Designated Authority was directed to continue the post-decisional hearing, and the time for completion was extended.

Final Conclusion: The challenge to the remand order failed, while the remand directions were preserved and operationalised by permitting the post-decisional hearing to proceed.

Ratio Decidendi: In the absence of an express statutory provision, a tribunal has no inherent power to review its final order, though it may undertake only such procedural directions as are necessary to carry out an existing remand and protect the parties' hearing rights.

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