https://www.taxtmi.com/caselaws?id=127126 A revision application under the Bombay Sales Tax Act could be filed directly without first exhausting an appeal, because the statutory scheme did not make prior appeal a universal prerequisite. Prepayment of assessed tax and penalty was not a condition precedent for every revision: Section 22 contained no express such requirement, and Rule 48, read with Form XXV, applied prepayment only to revisions arising from appellate orders. The text distinguishes this limited rule from Section 21, where the Legislature imposed an express prepayment condition, showing that the requirement could not be extended by implication. The revision was therefore maintainable in the first instance, and the matter was to be considered on merits. en-us Mon, 24 Sep 1951 00:00:00 +0530 Tue, 26 Feb 2013 18:32:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=127126 A revision application under the Bombay Sales Tax Act could be filed directly without first exhausting an appeal, because the statutory scheme did not make prior appeal a universal prerequisite. Prepayment of assessed tax and penalty was not a condition precedent for every revision: Section 22 contained no express such requirement, and Rule 48, read with Form XXV, applied prepayment only to revisions arising from appellate orders. The text distinguishes this limited rule from Section 21, where the Legislature imposed an express prepayment condition, showing that the requirement could not be extended by implication. The revision was therefore maintainable in the first instance, and the matter was to be considered on merits. Case-Laws VAT and Sales Tax Mon, 24 Sep 1951 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=127126