Statutory tribunal compliance powers allow fixed-time enforcement of its own order, but interest needs express statutory authority.

A statutory tribunal may direct implementation of its earlier specific order within a fixed time where only part-compliance has occurred, and may require the department to explain the default and file a compliance report. However, it cannot award interest on the amount due for non-compliance unless the governing statute expressly confers that power. The result was a direction for full compliance within two months, while the request for interest was refused for want of statutory authority.

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Issues: (i) whether directions could be issued for implementation of the Tribunal's earlier final order within a fixed time; (ii) whether interest could be awarded on the amount due for non-compliance.

Issue (i): Whether directions could be issued for implementation of the Tribunal's earlier final order within a fixed time.

Analysis: The order under implementation was specific and ought to have been complied with within a reasonable time. The Department was directed to ascertain the circumstances in which only part-compliance had taken place and to ensure full compliance within two months, with a compliance report to be filed on the returnable date.

Conclusion: Yes. A direction for compliance within two months was issued in favour of the assessee.

Issue (ii): Whether interest could be awarded on the amount due for non-compliance.

Analysis: No statutory provision was shown empowering the Tribunal to order payment of interest on the amount in question. Being a creature of statute, the Tribunal held that it must act within the limits of statutory authority and could not grant such relief in the absence of enabling provision.

Conclusion: No. The request for interest was rejected.

Final Conclusion: The application succeeded only to the extent of a direction for expeditious compliance of the earlier order, while the prayer for interest was declined.

Ratio Decidendi: A statutory tribunal cannot grant interest or analogous relief unless the governing statute expressly confers such power, though it may direct compliance with its earlier order.

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