Proper authorisation for signing tax appeals is mandatory; an appeal signed without valid authority is not maintainable.

An income-tax appeal filed by a company was required to be signed and verified by a person duly authorised under the statutory scheme and prescribed rules. The record did not show that the General Manager who signed the appeal held valid authority, and the company also failed to establish proper authorisation through the permitted mechanism. As the mandatory filing requirements were not satisfied, the appeal was defective and not maintainable. It was therefore dismissed in limine.

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Issues: Whether an appeal filed by a company through a signatory not shown to be authorised in the prescribed manner was maintainable and liable to be dismissed in limine.

Analysis: The appeal had to be signed and verified by a person authorised under the statutory scheme governing filing and verification of income-tax returns and appeals. The statutory provisions distinguished between classes of assessees and permitted filing through a power-of-attorney holder only in specified situations. The record did not establish that the General Manager who signed the appeal held a valid authority to do so. In the absence of proof of proper authorisation, the appeal did not satisfy the mandatory filing requirements.

Conclusion: The appeal was not maintainable and was rightly dismissed in limine.

Ratio Decidendi: An appeal under the income-tax appellate framework must be signed and verified by a person duly authorised by the statute and the prescribed rules; failure to establish such authority renders the appeal defective and liable to dismissal.

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