Binding appellate orders must be implemented; mandamus can compel compliance where a subordinate authority refuses to obey a clear direction.

A subordinate income-tax authority must comply with a final and binding appellate tribunal order; it cannot refuse implementation on the ground that the order is wrong or unclear. Where the Tribunal's direction is clear, the officer must give effect to it as issued, and a writ of mandamus is maintainable ex debito justitiae to enforce obedience. The refusal to implement the appellate order was treated as unlawful because it disregarded judicial hierarchy and amounted to denial of justice.

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Issues: Whether a writ of mandamus could issue to compel the Income-tax Officer to carry out the directions given by the Income-tax Appellate Tribunal, and whether a subordinate authority could refuse to act on a binding appellate order on the footing that the order was wrong or unclear.

Analysis: The Tribunal's order had become final and binding, and the Income-tax Officer was under a legal duty to give effect to it. A subordinate tribunal cannot disregard the directions of a superior tribunal in the exercise of appellate jurisdiction. The refusal to carry out such directions amounts to denial of justice and offends the basic principle of judicial hierarchy. The direction of the Tribunal was clear and unambiguous, and the Officer misread it by proceeding on an incorrect basis instead of ascertaining the average transport charges from the centres to the factory as directed.

Conclusion: A writ of mandamus was maintainable to compel compliance with the Tribunal's directions, and the Officer's refusal to implement the binding appellate order was unlawful.

Ratio Decidendi: A subordinate authority must obey and implement the directions of a superior appellate tribunal, and mandamus lies ex debito justitiae to enforce compliance with a final and binding order.

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