Statutory finality and implied exclusion of revision barred High Court revision after tribunal appeal under the sales tax scheme.

Where a special statute makes the Commissioner's decision final subject only to appeal to a designated tribunal, and the statute does not expressly provide a further revision, the High Court's revisional jurisdiction is excluded by necessary implication. The U.P. Sales Tax Act, 1948 was read as creating a distinct appellate scheme for orders under Section 35, with the Tribunal as the final appellate forum in such matters. The Commissioner's decision under Section 35 was treated as quasi-judicial, but that did not create an additional revisional remedy. The High Court's writ jurisdiction under Article 226 remained unaffected, though no revision lay.

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Issues: Whether a revision lay to the High Court against a decision of the Sales Tax Tribunal passed on appeal from the Commissioner's order under Section 35 of the U.P. Sales Tax Act, 1948.

Analysis: Section 35 provided that the Commissioner's decision was final, subject only to an appeal to the Tribunal. The appellate scheme treated appeals from orders under Section 35 distinctly by requiring disposal by a bench of three members. Section 11 of the Act conferred a limited revisional jurisdiction on the High Court in specified cases, but the statutory language did not indicate that a further revision would lie after the Tribunal had decided an appeal from the Commissioner's order. The decision of the Commissioner under Section 35 was held to be quasi-judicial, and the amended scheme showed a legislative intent to make the Tribunal the final appellate forum for such matters. The High Court's supervisory writ jurisdiction under Article 226 remained unaffected, but that was not the remedy in issue.

Conclusion: No revision lay to the High Court from the Tribunal's decision in such a case. The appeals therefore failed.

Ratio Decidendi: Where a special statute makes the Commissioner's decision final subject only to an appeal to a designated tribunal, and the statute does not expressly provide a further revision, the revisional jurisdiction of the High Court is excluded by necessary implication.

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