R. R. MISRA, J. ( 1 ) THE assessee, M/s. Super Cotton Bowl Refilling Works, Maunath Bhanjan, Azamgarh, is engaged in repairing and refilling of cotton bowl of old shaft which is used as a part of calendering machine in the textile industry. Cotton bowl is a shaft made of steel on which thick layer of cotton is affixed. It is used in the textile finishing industries as an essential part of the calendering machine. In the course of its use the cotton pasted on the shaft loses its thickness and shape and after sometime it requires repairing and refilling. ( 2 ) THE assessee moved an application under Section 35 of the U. P. Sales Tax Act (hereinafter called the Act) before the Commissioner, Sales Tax, for his opinion on certain points. The said points included as to whether the job of repairing and refilling of cotton bowl and the process involved therein amounts to "manufacture" or "sale" within the meaning of the aforesaid Act. The Commissioner of Sales Tax, videhis order dated 19th June, 1985, decided both the questions against the assessee. Aggrieved against the same, the assessee preferred an appeal before the sales Tax Tribunal. The Sales Tax Tribunal, vide its order dated 14th November, 1985, allowed the appeal in part. The Tribunal held that the process of repairing and refilling of cotton bowl of the customers does not amount to "manufacture" as defined under Section 2 (e-l) of the Act. It further held that such an activity of the assessee amounts to "sale" as defined under Section 2 (h)of the Act as amended by the U. P. Sales Tax (Amendment and Validation) Act, 1985. It is against the aforesaid decision of the Sales Tax Tribunal that both the assessee as well as the commissioner of Sales Tax have preferred the above revisions in this Court. ( 3 ) THESE revisions were formerly heard on merits, but at the time of dictation of judgment a question arose as to the maintainability of these revisions. The revisions were accordingly refixed for hearing on the point of their maintainability. Learned counsel for the parties have also been heard accordingly on the same. ( 3 ) THESE revisions were formerly heard on merits, but at the time of dictation of judgment a question arose as to the maintainability of these revisions. The revisions were accordingly refixed for hearing on the point of their maintainability. Learned counsel for the parties have also been heard accordingly on the same. ( 4 ) THE, point that arises for consideration in these revisions is as to whether in view of the words used in Sub-clause (5) of Section 35 of the Act which lays down that a decision given by the commissioner of Sales Tax under that Section shall, "subject to an appeal to the Tribunal, be final", these revisions filed by the parties are not maintainable in this Court. ( 5 ) SECTION 35 of the Act and the relevant provisions of Section 10 of the Act are reproduced below: 35. Determination of disputed question.- (1) If any question arises, otherwise than in a proceeding pending before a court or before an assessing authority under Section 7 or Section 21, whether, for the purposes of this Act, (a) any person or association of persons, society, club, firm, company, corporation, undertaking or Government department is a dealer; or (b) any particular thing done to any goods amounts to or results in the manufacture of goods within the meaning of that term; or (c) any transaction is a sale or purchase and, if so, the sale or purchase price, as the case may be, therefor; or (d) any particular dealer is required to obtain, or to apply for the renewal of registration; or (e) any tax is payable in respect of any particular sale or purchase and, if so, the rate thereof, the person or the dealer concerned may, after depositing the fee specified in Section 32, submit an application to the Commissioner of Sales Tax, along with such documents as may be prescribed. (2) The Commissioner of Sales Tax shall, after giving the applicant an opportunity of being heard, decide as he deems fit the question soarising: provided that, before giving "such decision, the Commissioner of Sales Tax may, in his discretion, ask an officer subordinate to him to make such inquiries as he considers necessary for the decision of the question. (2) The Commissioner of Sales Tax shall, after giving the applicant an opportunity of being heard, decide as he deems fit the question soarising: provided that, before giving "such decision, the Commissioner of Sales Tax may, in his discretion, ask an officer subordinate to him to make such inquiries as he considers necessary for the decision of the question. (3) No decision of the Commissioner of Sales Tax under this section shall affect the validity or operation of any order passed earlier by any assessing authority, appellate authority, revising authority or the Tribunal. (4) No question which arises from an order already passed, in the case of the applicant, by any authority under this Act or the Tribunal, shall be entertained for determination under this section. (5) A decision given by the Commissioner of Sales Tax under this section shall, subject to an appeal to the Tribunal, be final. (6) A copy of the decision given under this section shall be sent to the applicant and to the assessing authority concerned. ( 6 ) SUB-CLAUSES (9) and (10) of Section 10 read as follows : 10. (9) The members of the Tribunal shall sit in such benches of one, two or more members as may be constituted from time to time and do such work of the Tribunal as may, subject to sub-section (10) and the rules, be allotted to them, by order, or in accordance with the directions of the President of the Tribunal. (10) (a) An appeal against the order of appellate authority under Section 9 shall be heard and disposed of -. (i) by a bench of two members, where such order is passed by a Deputy Commissioner (Appeals)or the amount of tax, fee or penalty in dispute exceeds ten thousand rupees; (ii) by a single member in any other case. (b) An appeal against an order passed under Section 10b shall be heard and disposed of by a bench of two members. (c) An appeal against an order passed under Section 35, which shall be filed before the President, shall be heard and disposed of by a bench of three members. . . . (b) An appeal against an order passed under Section 10b shall be heard and disposed of by a bench of two members. (c) An appeal against an order passed under Section 35, which shall be filed before the President, shall be heard and disposed of by a bench of three members. . . . ( 7 ) IN order to find out as to what is the meaning to be attributed to the words "shall be final" as occurring in Sub-clause (5) of Section 35 of the Act, one has to look to the intention of the legislature. In legal sense the word "intention" conveys the idea of purpose behind the legislation. Ordinarily when we enquire about the intention of the legislature, we turn to the statute itself to see what the words actually mean in their respective settings. . As observed by the supreme Court in K. Narasimhiah v. H, G. Singri Gowda AIR 1966 SC 330 , to ascertain the intention, the court has to examine carefully the object of the statute, the consequences that may follow from insisting on a strict observance of the particular provision and above all the general scheme of the other provisions of which it forms a part. This is to be done after considering the pros and cons of the situation. ( 8 ) A perusal of the provisions of Section 35 of the Act discloses that the said Section is a complete code in itself for determination of disputed questions. It also lays down the scope of the authority of the Commissioner of Sales Tax to entertain the disputed questions. Sub-clause (4) of section 35 of the Act states that no question which arises from an order already passed in the case of the applicant, by any authority under this Act (or the Tribunal) shall be entertained for determination under this section. Sub-clause (3) thereof lays down that the decision of the commissioner of Sales Tax under Section 35 of the Act shall not affect the validity or operation of any order passed by any authority under the Act or the Tribunal. ( 9 ) WITH the aforementioned conditions, the Commissioner enters into determination of the disputed questions. Sub-clause (2) of Section 35 of the Act enjoins on the Commissioner to decide the questions referred to him as he deems fit after giving the applicant an opportunity of being heard. ( 9 ) WITH the aforementioned conditions, the Commissioner enters into determination of the disputed questions. Sub-clause (2) of Section 35 of the Act enjoins on the Commissioner to decide the questions referred to him as he deems fit after giving the applicant an opportunity of being heard. Under Sub-clause (5) of Section 35 it has been stated that a decision given by the commissioner of Sales Tax shall, subject to an appeal to the Tribunal, be final. ( 10 ) WHEN we come back to the appeal to the Tribunal, we find that in regard to an appeal against an order passed under Section 35, the appeal is to be heard and disposed of by a bench of three members, although in regard to other appeals before the Tribunal they can be disposed of even by a single member or by a bench consisting of two members. ( 11 ) IT is noteworthy to find that under Sub-clause (5) of Section 35 of the Act prior to its amendment by U. P. Act No. 12 of 1979, an appeal used to lie to the High Court against an order of the Commissioner of Sales Tax. By the aforesaid amendment brought by U. P. Act No. 12 of 1979, under Sub-clause (5) of Section 35 the words "high Court" have been deleted and substituted by the word "tribunal". As I have already indicated above, in so far as appeal before the Tribunal against an order passed under Section 35 is concerned, special treatment has been provided for by the legislature. A further safeguard has also been provided for, inasmuch as when such an appeal is brought before the Tribunal, it has to be filed before the President of the tribunal and has to be disposed of by a bench of not less than three members. ( 12 ) AN argument has been raised on behalf of the State that since the Tribunal disposed of the appeal under Section 10 of the Act, therefore, the said order became the subject-matter of revision before the High Court under Section 11 of the Act. ( 12 ) AN argument has been raised on behalf of the State that since the Tribunal disposed of the appeal under Section 10 of the Act, therefore, the said order became the subject-matter of revision before the High Court under Section 11 of the Act. ( 13 ) I find that recently a Division Bench of this Court in the case of Indo Lube Refineries, gorakhpur v. Sales Tax Officer, Gorakkpur 1986 UPTC 1365 has taken the view that an order passed by the Commissioner under Section 35 of the Act is an administrative order and in so doing he does not act as a Tribunal. It has also been held that although after the Commissioner has passed an order under Section 35 no further dispute can be raised before him but this will not debar the other authorities under the Act from deciding the controversy before it on its own. In other words, the order passed by the Commissioner of Sales Tax under Section 35 is not binding on the Sales Tax Officer or the Assistant Commissioner (Judicial) while exercising quasi-judicial functions. The argument raised on behalf of the other side is that if the provisions of Sub-clause (2) of Section 35 are taken into account which lays down that while passing an order under section 35 the Commissioner of Sales Tax shall, after giving the applicant an opportunity of being heard, decide as he deems fit, this in itself indicates that the proceedings before the commissioner are not administrative but are quasi-judicial in nature. Be that as it may, but sitting singly I am bound by the aforesaid Division Bench decision in the case of Indo Lube refineries 1986 UPTC 1365 and in view of that decision it has to be held that the order passed by the Commissioner of Sales Tax under Section 35 is administrative in nature. If the order passed by the Commissioner of Sales Tax is administrative in nature, an appeal taken to the tribunal against the said order will not, in my opinion, change the nature and character of the order. In such a situation, it cannot be contemplated that the legislature intended an administrative order also to be taken in revision before the High Court and thereafter in appeal to the Supreme Court. In such a situation, it cannot be contemplated that the legislature intended an administrative order also to be taken in revision before the High Court and thereafter in appeal to the Supreme Court. ( 14 ) HAVING regard to the scheme of the aforesaid provisions and the amendment made by U. P. Act No. 12 of 1979 and the decision of the Division Bench afore- said, in my opinion the interpretation that is to be put on the words "shall be final" as occurring in Sub-clause (5) of section 35 of the Act is that after an appeal against an order under Section 35 of the Act is decided by the Tribunal, no further revision lies to the High Court. Any other interpretation of the words "shall be final" as occurring in the aforesaid sub-clause will render the same redundant. ( 15 ) THE counsel for the parties have, however, made a prayer that these revisions may be converted into writ petitions. The said prayer is, however, refused. ( 16 ) IN the result, both the revisions are dismissed as not maintainable. Parties to bear their own costs. .