Express statutory appeal rights govern cancellation of firm registration renewal; rule-based orders cannot be treated as appealable by implication.

A right of appeal in tax matters exists only where the statute expressly provides it, and an order not specifically made appealable cannot be treated as appealable by construction. Rule 6B was upheld as a valid ancillary rule enabling cancellation of renewal where a firm was not genuine, but section 30(1) was confined to the orders expressly made appealable by the Act. Because the Act made refusal to register and certain cancellation orders appealable but did not expressly provide an appeal against cancellation under rule 6B, such an appeal was unavailable.

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Issues: Whether an order passed under rule 6B of the Indian Income-tax Rules cancelling renewal of registration of a firm is appealable under section 30(1) of the Indian Income-tax Act.

Analysis: Rule 6B was treated as a valid ancillary rule made to carry out the purpose of section 26A and to enable cancellation where registration had been granted to a non-genuine firm. However, the appeal provision in section 30(1) was held to be confined to the specific orders made appealable by the Act. Since the Act expressly made refusal to register appealable and separately provided for appeal against cancellation in the case covered by section 23A, but contained no express right of appeal against cancellation under rule 6B, no such appeal could be implied or constructed by treating the order as if it were a refusal under section 26A.

Conclusion: An order under rule 6B cancelling renewal of registration is not appealable under section 30(1) of the Indian Income-tax Act.

Ratio Decidendi: A right of appeal in tax matters exists only where the statute expressly provides it, and an order not specifically made appealable cannot be treated as appealable by construction merely because it relates to proceedings under the same statutory scheme.

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