Finality of tribunal orders limits subordinate tax authority power to alter exemption commencement under Section 4-A(3).

Once the Tribunal had restored the assessee's eligibility certificate and that adjudication had attained finality, the Commissioner could not invoke Section 4-A(3) of the Sales Tax Act, 1948 to alter the commencement date of exemption or otherwise neutralise the Tribunal's order. The power of correction or modification did not extend to reopening a concluded decision of a superior forum, and any challenge or clarification had to be pursued before the Tribunal or in revisional jurisdiction. The restored eligibility certificate therefore remained beyond the Commissioner's suo motu interference, and the legal position favoured the assessee.

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Issues: Whether the Commissioner, Trade Tax could, after the Tribunal had restored the eligibility certificate, again alter the commencement date of exemption by invoking Section 4-A(3) of the Sales Tax Act, 1948.

Analysis: The eligibility certificate granted by the Divisional Level Committee had been restored by the Tribunal after setting aside the Commissioner's earlier order. Once that adjudication attained finality, the Commissioner had no authority to reopen the matter suo motu and vary the consequences of the Tribunal's decision. Any correction, clarification, or modification could have been sought only from the Tribunal or through challenge to that order in revisional jurisdiction. The power under Section 4-A(3) did not extend to overruling or neutralising a concluded adjudication by a higher forum.

Conclusion: The Commissioner lacked jurisdiction to modify the restored eligibility certificate, and the issue was decided in favour of the assessee and against the Revenue.

Ratio Decidendi: An authority exercising subordinate statutory power cannot alter or defeat the effect of an order that has attained finality before a superior adjudicatory forum.

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