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M/S. Godrej Sara Lee Ltd. vs The Excise And Taxation Officer Cum ... on 1 February, 2023

9. Having regard thereto, and the specific observation of the Hon'ble Supreme Court wherein it held that the Tribunals will consequently also have the power to test the vires of subordinate legislations and rules, however, this power of the tribunal will be subject to one important exception that the tribunal shall not entertain any question regarding the vires of their parent statutes following the settled principle that a tribunal which is a creature of an Act cannot declare that very Act to be unconstitutional, and since the petitioner only questions an entry under the said Act as ultra vires the said Act, the writ petition, in my view is not maintainable before this Court at the first instance. Although, Mr. Sachdeva has placed lot of stress on the judgment delivered in the case of Godrej Sara Lee Ltd. (supra) to drive home the point that this Hon'ble Court in exercise of its constitutional writ jurisdiction is competent to entertain a writ petition of this nature, I find that the facts based on which the judgment was delivered in the case of Godrej Sara Lee Ltd. (supra) are entirely different. The question that fell 10 for consideration in the said special leave petition was whether the High Court was justified in declining interference on the ground of an alternative remedy in the form of an appeal under Section 33 of the VAT Act. Such is not the case here. In the instant case, the order passed by the West Bengal Commercial Taxes Appellate and Revisional Board, having regard to the provisions contained in Section 5, 6 and 14 of the Tribunal Act 1987 can only be questioned before a Tribunal with a right of a further judicial review before the Divisional Bench under Article 226 of the Constitution of India. In view thereof, I am unable to accept the contentions of Mr. Sachdeva and the judgments cited by him do not assist the petitioner.
Supreme Court of India Cites 19 - Cited by 72 - D Datta - Full Document
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