1. MR. JUSTICE MIAN SAQIB NISAR.-(1). All the matters, specified in the Schedule attached to the judgment, are being decided together as these involve the common questions of law. However, it may be mentioned that these (matters) relates to three different laws i.e. Customs Act, 1969, Sales Tax Act, 1990 and Federal Excise Act, 2005.
2. In all- the cases, it is the stance of the petitioner-department that the impugned orders passed by a Single Member of the Customs, Excise & Sales Tax Appellate Tribunal (hereinafter referred to as the "Tribunal")'' are in violation of the relevant provisions of the respective laws, and thus, without jurisdiction.
3. Mr. Izharul Haque, the Learned counsel for the petitioners in the category of custom cases, submits that according to Section 194-C of the Customs Act, 1969, a Single Member of the Tribunal shall only be empowered and vested with the jurisdiction to decide the matter before it, if he was a part of the Bench of more than one member to which the case has been originally assigned, but for certain reasons could not be decided by such a Bench, and thereafter was assigned/entrusted to a Single Member for the disposal by the Chairman of the Tribunal. In relation to sales tax cases, by making reference to Section 46 read with Section 2 of the Sales Tax Act, 1990, the same legal submission has been propounded; homologous plea has been raised in the context of the matters relating to the Federal Excise Act, 2005 by referring to Section 34(2) thereof and also the definition clause (Section 2).
4. The learned counsel for the respondent has controverted the above plea and it is submitted that even a Single Member of the Tribunal has the power to decide a matter subject to the only condition that the matter should have been entrusted to him by the Chairman, which is the position in these cases and, therefore, considering the proposition in the light of Rule 2(1 )(c) of the Customs, Excise and Sales Tax Appellate Tribunal (Procedure) Rules, 2006, the Bench even comprising of a Single Member shall be the Bench having jurisdictional competence to take the decision. A preliminary objection has also been raised by the respondents' side that this Court in connection with all the three categories of the matters, can only examine a question if it arises out of the order, the plea propounded by the petitioner may relate to the aspect that the orders are without jurisdiction or coram non judice, and the petitioner may have a remedy to challenge those independently in the constitutional jurisdiction, but not within the scope of the relevant provisions of the law under which, the High Court can be approached for the determination of a specific legal point alone. About the connotation/expression arising out of the order, Mr. M.M. Akram, the learned counsel for the respondents in some cases, has placed reliance upon Azad Jammu and Kashmir Logging and Saw Mills Corporation through Chairman and Managing Director vs. Collector Central Excise and Sales Tax, Muzaffarabad and another (2005 PTD 1998) and Collector of Customs, Excise and Sales Tax Appellate Tribunal vs. Pakistan State Oil Company Ltd. (2005 PTD 2446). He has also argued that the alleged lapse is of procedural nature and on account of this, no prejudice has been caused to the petitioners; reliance in this behalf is placed on Dar Okaz Printing and Publishing Limited Liability Company vs. Printing Corporation of Pakistan - Private Limited (PLD 2003 SC 808) and The State v.v. Asif Adil and others (1997 SCMR 209). Mr. Azmat Lodhi, Advocate while drawing support from the judgment Messrs Nisbat Mills Limited v.v. Superintendent of Central Excise Circle II and 3 others (PLD 1989 SC 222) has invoked the principle of 'substantial compliance' and also states that it is not the case of the petitioners that the Single Member otherwise lacked the pecuniary, subject matter or territorial jurisdiction. Mr. Umair Arshad Hakim, the Learned counsel for the respondents' side states that Sections 194/195 of the Customs Act, 1969 shall not be applicable to the matters pertaining to the Sales Tax as the specific relevant provisions of the Sales Tax Act itself provides a procedure as to how the matter before the Tribunal should be conducted and decided; he has drawn support from Collector of Customs, Model Customs Collectorate of PACCS, Karachi vs. Muzammil Ahmad (PTCL 2009 CL. 477). Mr. Aamer Faruq, Advocate has argued that the Single Member has the jurisdiction and the word "bench" does not necessarily mean a to members bench or more, it can always be a bench of one member. Malik Mehmood, one of the respondents' counsel, by relying upon the judgment reported as Messrs Rahim Electric Store, Faisalabad vs. Secretary, Revenue Division, Islamabad (2003 PTD 187) has argued that the objection about the jurisdiction should be taken first before the Tribunal and if not so done or otherwise determined by the Tribunal, it shall not be a question which arises out of the order of the Tribunal and, therefore, cannot be adjudicated in the constitutional jurisdiction.
5. Responding and controverting the above, Mr. Izharul Haque, the learned counsel for the petitioners, has relied upon Abdul Ghaffar Lakhani vs. Federal Government of Pakistan and 2 others (PLD 1986 Karachi 525) and James Patrik & Co. Proprietary Ltd. Vs. Dacie Ethel Sharpe (PLD 1955 PC 82) and Article 199(3) of the Constitution of Islamic Republic of Pakistan, 1973 while submitting that the expression arising out of the order is all embracing and thus the question of jurisdiction shall fall within the ambit thereof.
6. Heard. There are to key questions involved in the matter:
(1) Whether the order passed by the Tribunal on account of the plea propounded is without jurisdiction or coram non judice, and thus shall be considered to be a question arising out of the order of the Tribunal and can be determined in the references/appeals under the noted laws;
(2) Whether the matter if directly entrusted to a Single Member Bench without it being first assigned to a bench of to or more members can be held to be violative of the various relevant provisions of the concerned statutes.
7. In order to dilate upon the questions, it shall facilitate if the relevant provisions of Sections 194-C and 196 of the Customs Act, 1969, Sections 46, 47(1) and 2(1) of the Sales Tax Act, 1990, and Sections 34(2)(3) and 2(3) of the Federal Excise Act, 2005 and the Rules there-under be reproduced in the seriatim: Section 194-C of the Customs Act. 1969: "194-C. Procedure of Appellate Tribunal.- (1) The powers and functions of the Appellate Tribunal may be exercised and discharged by Benches constituted by the Chairman from amongst the members thereof.
(2) Subject to the provisions contained in sub-sections (3) and (4), a bench shall consist of one judicial member and one technical member.
(3) Every appeal against a decision or order [deciding a case involving duty, tax, penalty or fine exceeding five million rupees] shall be heard by a Special Bench constituted by the Chairman for hearing such appeals and such Bench shall consist of not less than to members and shall include at least one judicial member and one technical member: Provided that the Chairman may, for reasons to be recorded in writing, constitute Benches including special Benches consisting of--
(a) to or more technical members; or
(b) to or more judicial members.
2. (3A) Notwithstanding anything contained in sub-sections (2) and (3), the Chairman may constitute as many Benches consisting of a single member as he may deem necessary to hear such cases or class of cases as the Federal Government may, by order in writing, specify.
(4) The Chairman or any other member of the Appellate Tribunal authorized, in this behalf by the Chairman may, sitting singly, dispose of any case which has been allotted to the bench of which he is a member (emphasis supplied) where-
(a) ---------------------------------------------------
(b) * * * * * * * * *
(c) --------------- Section 196 of the Customs Act. 1969: "196. Reference to High Court.-(1) Within ninety days --- the aggrieved person or Collector -------- -------------------------------------may prefer an application, in the prescribed form alongwith a statement of the case, to the High Court, stating any question of law arising out of such order.
(2) The statement to the High Court, referred to in sub-section (1), shall set out the facts, the determination of the Appellate Tribunal and the question of law, which arises out of such order.
(3) Where, on an application made under sub-section (1), the High Court is satisfied that a question of law arises out of the order, referred to in sub-section (1), it may proceed to hear the case.
(4) ---------------------------------------
(5) The High Court upon hearing a reference under this section shall decide the question of law raised by the reference and pass judgment thereon specifying the grounds on which such judgment is based and the Tribunal's order shall stand modified accordingly.
3. Section 46. Section 47(1~) & Section 2(11 of the Sales Tax Act. 1990: Section 46 of the Sales Tax Act.
4. 1990: "46. Appeals to Appellate Tribunal.- (1) Any person including an officer of Sales Tax not below the rank of an Additional Collector, aggrieved by any order passed by-
(a) the Collector of Sales Tax (Appeals) under section 45B,
(b) the Collector of Sales Tax through adjudication or under any of the provisions of this Act or rules made thereunder,
(c) the Board under section 45A, may, within sixty days of the receipt of such decision or order, prefer appeal to the Appellate Tribunal. ----------------------------------------------------------------------------------------- -------------------------------------------
(9) The Chairman or any other member of the Appellate Tribunal authorized in this behalf by the Chairman may, sitting singly, dispose of any case which has been allotted to the bench of which he is member (emphasis supplied) where-
(a) ----------
(b) ----------- Section 47(11 of the Sales Tax Act. 1990: "47. Reference to High Court.-(1) Within ninety days----------------------------- the aggrieved person or any officer of Sales Tax not below the rank of a Deputy Collector may prefer an application in the prescribed form alongwith a statement of the case to the High Court, stating any question of law arising out of such order."
5. Section 2(11 of the Sales Tax Act. 1990: "2. Definitions.- In this Act, unless there is anything repugnant in the subject or context,-
(1) "Appellate Tribunal" means the Customs, Excise and Sales Tax Appellate Tribunal constituted under section 194 of the Customs Act."
6. Section 34(21(31 and Section 2(31 of the Federal Excise Act. 2005: Section 34(2)(3) of the Federal Excise Act. 2005: "34. Appeals to the Appellate Tribunal and Reference High Court.-
(1) ..........................
(2) The Appellate Tribunal may, in its discretion, refuse to admit an appeal in respect of an order referred to in sub-section (1) where,-
(a) in any disputed case, other than a case where the determination of any question having a relation to rate of duty of excise or to the value of goods and services for purposes of assessment is in issue or is one of the points in issue, the difference in duty involved or the duty involved; or
(b) the amount of fine or penalty determined by such order; does not exceed five hundred thousand rupees.
(3) Within ninety days of the date on which an order of the Appellate Tribunal is communicated to him, the aggrieved person or any officer of Federal Excise not below the rank of Additional Collector, authorized by the Collector may prefer an application in the prescribed form alongwith a statement of the case, to the High Court, stating any question of law arising out of such order."
7. Section 2(3) of the Federal Excise Act. 2005: "2. Definitions.
(1) ----------------------
(2) ---------------------
(3) "Appellate Tribunal" means the Customs, Excise and Sales Tax Appellate Tribunal constituted under section 194 of the Customs Act, 1969 (IV of 1969)."
8. Rule 51 of the Federal Excise Rules. 2005 provides: "Procedure of Appellate Tribunal.- (1) The provisions of sub-sections (1) , (2), (5) and (6) of section 194-C of the Customs Act, 1969 (IV of 1969) shall apply to the Appellate Tribunal in the discharge of its functions under the said Act.
(2) Every appeal against a decision or order relating, among other things, to the determination of any question having a relation to the rate of duty of excise or to the value of excisable goods and services for purposes of assessm ent, shall be heard by a Special Bench constituted by the Chairman of the Tribunal for hearing such appeal and such Bench shall consist of not less than to members and shall include at least one judicial member and one technical member.
(3) The Chairman or any other member of the Tribunal authorized in this behalf by the Chairman may, sitting singly, dispose of any case which has been allotted to the Bench of which he is a member where:---------------------------------------------------------------."
9. Besides, Rule 2(1 )(c) of the Customs, Excise and Sales Tax Appellate Tribunal (Procedure) Rules, 2006, which is expedient for consideration in the matter, reads as below: "2. Definitions.--(1) In these rules, unless there is anything repugnant in the subject or context,
(a) --------------------------------------------------
(b) --------------------------------------------------
(c) "bench" means the Bench of the Tribunal constituted under sub-section (1) of section 194-C of the Customs Act, 1969 and includes Special Bench and any other Member sitting singly under the proviso to sub-section (7) of the said section."
8. At the inception of hearing these matters, as it was not clear if those (matters) were directly entrusted to the Single Member Bench or subsequently by the Chairman of the Tribunal, therefore, the information was sought from the Chairman, who has produced on the record a complete data regarding all the matters, which has been made part of this case (i.e. C.A. No. 12 of 2005). From the examination whereof, it transpires that all the matters mentioned in the Schedule hereto were never initially/originally or thereafter entrusted/assigned to a Bench of to members, but under some administrative arrangement, were directly marked to the Single Member by the Registrar of the Tribunal and the Chairman has not played any role or exercised its due authority in this regard.
9. Be that as it may, addressing question No. 2 first, it may be held that the interpretation of the relevant provisions invoked in these cases needs to be structured on the three foundational, settled and the tested principles; (i) the golden rule of construction, (ii) no redundancy and/or superfluity can be imputed to the express provision and words of statute, (i.e) where the law requires an Act to be performed or a thing to be done in a particular maimer it has to be so performed/done. The Golden Rule, has been articulately enunciated in Statutory Interpretation by Cross-P-15, in the following words: "I have been long and deeply impressed with the wisdom of the rule now, I believe, universally adopted, at least in the courts of law in Westminster Hall, that in construing wills and indeed, statutes, and all written instruments, all grammatical and ordinary sense of the words is to be adhered to, unless that would lead to some absurdity, or some repugnance or inconsistency with the rest of the instrument, in which case the grammatical and ordinary sense of the words may be modified, so as to avoid the absurdity and inconsistency but no farther."
10. Thus, considering and construing Section 194-C(3)(4) of the Customs Act, 1969 and Section 46(9) of Sales Tax Act, 1990, from the plain reading thereof, it is abundantly clear that the Single Member Bench of the Tribunal has the jurisdiction to decide certain class of cases, but the jurisdiction is dependent and circumvented by certain conditions, especially with reference to sub-section (4), of entrustment/allocation by the Chairman, which authority of the Chairman is circumscribed that such matter/case should have been earlier allotted to a Bench of which the Single Member should be a part/a Member. The words "of which he is a member" appearing in the section are of immense and fundamental importance for the interpretation thereof, which necessarily means that he should be a Member of that Bench, which composes and comprising of more than one Member Bench. If the noted expression is interpreted otherwise, this part of the section shall be rendered redundant and superfluous, which flaw, fault and misstep cannot be attributed to the legislative instrument, especially when the words are quite lucid, lambert, lucent and refulgent. In our view, it is specifically and expressly the Chairman who has been empowered to meet certain exigencies such as, where the case was entrusted and being heard by the bench of more than one member, but due to certain circumstances, which may be innumerable, such as, one of the members, going for a long leave, retirement, being posted to some other seat of the Tribunal, demise of a member, member technical being repatriated to the department etc. And the matter being a part-heard or even, otherwise, the Chairman of the Tribunal could exercise the power of entrusting the case, keeping in view the expediency and exigency for the hearing by a Single Member, but, while exercising this authority, such Bench shall obviously be that Single Member Bench, who (the Member) was the Member of that Bench, comprising of to members, to which the matter was originally allocated; this authority of the Chairman is not a routine, incidental and ministerial in nature, rather from the very spirit of the law, it requires a proper application of mind to decide in the first place whether a particular matter should be so sent or not; is such a matter capable of being handled singly by the Member (Judicial) or Member (Technical) on account of its nature and the question involved therein; in any case, such an authority, at the very inception when a case is initiated with the Tribunal or during the pendency thereof, cannot be delegated to the Registrar on account of the rule that where an authority has been conferred upon a particular person/officer, it has to be exercised by him alone and cannot be further delegated, this principle has the nexus with the maxim delegatus non potest delegare. Any other interpretation placed to the requisite section, in our view, would militate against the clear intent of the legislature and also the rules of interpretation/law noted above, which is not permissible. The pleas of the respondents' side regarding the principle of "substantial compliance" or "procedural in nature" are not attracted to the matters, as it is the question regarding the conferment of jurisdiction unto the Single Member Tribunal in the specific manner ordained by law, and as mentioned earlier, the authority of the Chairman in this behalf is not exercisable as a matter of course, routine and in a clerical way, but is dependent upon the due application of the mind by the Chairman as to which case should be allotted to the Single Member Bench keeping in view the various aspects of the case, some of which have been highlighted above. Thus, such a question about the exercise of authority and jurisdiction cannot be equated to mere a procedural/substantial compliance rule. The interpretation placed for Section 194-C of the Customs Act, 1969, on account of homologous provision of the Sales Tax Act, 1990. Section 46(9) shall be aptly applicable as same shall be our decision with regard thereto. Therefore; we are of the considered view that the matters falling within the purview of the Custom and Sales Tax Law, which have been directly entrusted to the Member by the Registrar of the Tribunal are hit by the relevant sections, reproduced above, and the orders impugned in the matters mentioned in the Schedule on that account cannot sustain for the error of jurisdiction.
10. In respect of the Excise matters, one may however, argue that on account of lack of akin and similar provision in the Federal Excise Act, 2005, and no reference about the applicability of the provisions of the Customs Act, 1969, even the Single Member can pass any order, suffice it to say that the 'Tribunal' has been defined in Section 2(3) of the Act, 2005 to mean the one constituted under Section 194 of the Customs Act, 1969. Thus, this brings the case within the purview and the concept of legislation by reference and as the Tribunal is the Appellate Tribunal for deciding the excise category of the case as well, it shall mean that the Tribunal and its Chairman is clothed with all the power conferred by the Customs Act, 1969 under which, the Tribunal has been primarily constituted, because there is no specific procedure enunciated by the Federal Excise Act, 2005 to the contrary. Rather, the powers of the Chairman provided in Rule 51 of the Federal Excise Rules, 2005, are in consonance with Section 194-C(4) and Section 46(9) ibid, and eliminates any doubt in this respect, as its language is absolutely at parity with that of the to sections (of Customs & Sales Tax). Therefore, on this score as well, the authority of the Chairman of the Tribunal, as a body whole, has to be constructed in the same manner with all the exactitude of the other to laws. Resultantly, for this category of the cases also, our view is the same.
11. Now considering the first question, it may be mentioned that the real object of providing a special appeal/reference to the High Court in these fiscal matters is confined and restricted only to the question of law. Such question necessarily should emanate, spring up, originate and stem from the proceedings, which have reached the Appellate Tribunal and certainly must be spelt out from the order of the Tribunal itself. Where such a legal question, be that of jurisdiction either of the forums below in hierarchy of the Tribunal or the Tribunal itself, it should be agitated before the said forum and on account of analyzing the orders, it should emerge for the determination, but if not, it cannot be held to be that question of law arising out of the order, regarding which appeal/reference has been provided to the High Court under the special laws, in line with the object, purpose and spirit of the law, therefore, a restricted and circumscribed interpretation should be placed in construing the expression 'arising out of the order'. While considering an analogous proposition, it has been held in Azad Jammu and Kashmir Logging and Saw Mills Corporation through Chairman and Managing Director vs. Collector Central Excise and Sales Tax, Muzaffarabad and another (2005 PTD 1998) that:- "---------- , the scope of appeal before the High Court is limited and dependent upon such questions which arise out of the order of the Tribunal. This Court has the and again repeatedly laid down that when an at is prescribed to be done in a particular way, it must be performed accordingly or not at all..........................................................
11. In Collector of Customs, Excise and Sales Tax Appellate Tribunal vs. Pakistan State Oil Company Ltd.
12. (2005 PTD 2446), while considering the connotation and the scope of jurisdiction exercisable by the High Court in respect of the question of law arising out of the order, it has been held:- "11. Perusal of section 196 of the Act reveals that High Court can exercise its jurisdiction only in respect of questions of law arising out of order under section 194-B of the Act. It is significant to note that before the Customs hierarchy plea of limitation was not raised. It being so, the High Court was not competent to consider said plea, as it was neither raised before Collector Customs, nor before the Tribunal. There is no discussion on the point of limitation in the orders passed by the Collector Customs and the Tribunal. Question of limitation is a mixed question of law and fact and unless it was raised before the forum below, it could not straightaway be agitated before High Court. It can be concluded that such question never arose from the order passed by the Tribunal.
13. Factual controversy is sorted out up to the level of the Tribunal. Remedy under section 196 is restricted to legal points only, which was not available to the respondent-Company before High Court."
14. This view also finds support from the ratio of the judgment of a Division Bench of the Sind High Court reported as Collector of Customs, Model Customs Collectorate of PACCS, Karachi vs. Muzammil Ahmad (PTCL 2009 CL. 477).
12. In our view, the expression 'arising out of the order' is to be interpreted and applied in the context of the law in which the empowerment has been provided to the High Court to decide certain cases.
15. The jurisdiction of the High Court in this behalf is limited only to the question of law, which as stated earlier emerges out of the impugned order of the Tribunal before the High Court or even from the orders of the forums lower in the departmental hierarchy, but not any supplemented, incidental or an ancillary question which was not in issue in these proceedings; therefore in appeals/references under the special law, no collateral attack to the order of the Appellate Tribunal can be made even if based upon the lack of jurisdiction. The judgments cited by Mr. Izharul Haque, Advocate reported as Abdul Ghaffar Lakhani w. Federal Government of Pakistan and 2 others (PLD 1986 Karachi 525) and James Patrik & Co. Proprietary Ltd. Vs. Dacie Ethel Sharpe (PLD 1955 PC 82) are distinguishable on their own facts and cannot be considered relevant to construe the provisions in a fiscal statute, which provided appeal/reference with a specific object behind it i.e. Limiting the extent of the jurisdiction of the High Court only to the question of law which flows and originates from the order itself. Therefore, we are of the candid consideration that the orders of the Tribunal which have been challenged before us cannot be set aside while exercising our special jurisdiction available for special purpose under the specific law, but we find weight in the request of the Learned counsel for the petitioners that as the orders passed by the Single Member are without jurisdiction, therefore, these appeals/references be converted into constitution petitions and while exercising the constitutional jurisdiction under Article 199 of the Constitution of Islamic Republic of Pakistan, 1973, the orders be set aside. The respondents' side has also, while arguing and resisting the plea of the petitioners to challenge these orders in the present proceedings, has submitted that the constitutional jurisdiction should have been invoked. Lest a fresh exercise is made, which shall be the wastage of the of this Court, because the answer to question No. 2 has been categorically provided, therefore, we accede to the request of the petitioners' counsel and allow the conversion of the present matters into constitution petitions; the Office is required to number these cases as writ petitions with the further direction that the petitioners shall affix the requisite court fee within a period of to months and the matters are remanded to the Tribunal for decision afresh in accordance with law. In case, the. Requisite court fee is not paid within the the provided, the plea of the petitioners about the jurisdiction shall be deemed waived by it and also to have been rejected by this Court and the matters as references/appeals shall be listed only to consider the question of law, if any left in the matters except that of the jurisdiction.
16. In the light of above, all those matters, mentioned in the Schedule, which on account of the data provided by the Chairman of the Tribunal were not ever assigned to the Bench of more than one Member rather directly to the Member, subject to the above, are allowed as the Constitution Petitions (emphasis added), while the other matters, which have been entrusted to the Bench first and thereafter allotted to the Single Member by the Chairman of the Tribunal, shall be set out for hearing.
17. C.A. No. 12 of 2005.
18. SCHEDULE Matters directly assigned to the Member:
1. Custom Appeal No. 12 of 2005.
19. 2.Custom Appeal No. 13 of 2005.
20. 3.Custom Reference No. 1 of 2009.
21. 4.Custom Reference No. 14 of 2009.
22. 5.Custom Reference No. 16 of 2009.
23. 6.Custom Reference No. 20 of 2009.
24. 7.Custom Reference No. 24 of 2009.
25. 8.Custom Reference No. 25 of 2009.
26. 9.Custom Reference No. 28 of 2009.
27. 10.Custom Reference No. 29 of 2009.
28. 11.Custom Reference No. 30 of 2009.
29. 12.Custom Reference No. 34 of 2009.
30. 13.Custom Reference No. 35 of 2009.
31. 14.Custom Reference No. 36 of 2009.
32. 15.Custom Reference No. 37 of 2009.
33. 16.Custom Reference No. 38 of 2009.
34. 17.Custom Reference No. 39 of 2009- 599/LB/2009.
35. 18.Custom Reference No. 40 of 2009.
36. 19.Custom Reference No. 43 of 2009.
37. 20.Custom Reference No. 45 of 2009.
38. 21.Custom Reference No. 46 of 2009.
39. 22.Custom Reference No. 50 of 2009.
40. 23.Custom Reference No. 51 of 2009.
41. 24.Custom Reference No. 52 of 2009.
42. 25.Custom Reference No. 53 of 2009.
43. 26.Custom Reference No. 60 of 2009.
44. 27.Custom Reference No. 61 of 2009.
45. 28.Custom Reference No. 64 of 2009.
46. 29.Custom Reference No. 67 of 2009.
47. 30.Custom Reference No. 68 of 2009.
48. 31.Custom Reference No. 69 of 2009.
49. 32.Excise Tax Reference No. 4 of 2009.
50. 33.Sales Tax Reference No. 28 of 2009.
51. 34.Sales Tax Reference No. 30 of 2009.
52. 35.Sales Tax Reference No. 35 of 2009.
53. 36.Sales Tax Reference No. 36 of 2009.
54. 37.Sales Tax Reference No. 37 of 2009.
55. 38.Sales Tax Reference No. 38 of 2009.
56. 39.Sales Tax Reference No. 39 of 2009.
57. 40.Sales Tax Reference No. 40 of 2009.
58. 41.Sales Tax Reference No. 41 of 2009.
59. 42.Sales Tax Reference No. 42 of 2009.
60. 43.Sales Tax Reference No. 43 of 2009.
61. 44.Sales Tax Reference No. 46 of 2009.
62. 45.Sales Tax Reference No. 47 of 2009.
63. 46.Sales Tax Reference No. 48 of 2009.
64. 47.Sales Tax Reference No. 51 of 2009.
65. 48.Sales Tax Reference No. 65 of 2009.
66. 49.Sales Tax Reference No. 71 of 2009.
67. 50.Sales Tax Reference No. 78 of 2009.
68. 51.Sales Tax Reference No. 79 of 2009.