Judgment :- A. S. ANAND, C.J. The Revenue is in revision in the aforesaid tax cases against the order of the Sales Tax Appellate Tribunal (Additional Bench), Coimbatore, remitting the appeals filed by the assesses to the assessing officer for fresh disposal in accordance with law and in the light of the observations made by the Tribunal in its order dated 31st March, 1981. 2. Brief facts relating to the filing of the appeals before the Tribunal need mention at this stage. The respondents in these tax revision cases are manufacturers-cum-dealers in gingelly oil and oil cakes. They had purchased gingelly seeds and oil cakes during the assessment years in question from unregistered dealers. The gingelly seeds had been consumed by the respondents-assessees in the manufacture of gingelly oil, and gingelly oil cakes had been dispatched to places outside the State otherwise than in the course of inter-State trade and commerce. The purchase of gingelly seeds had not suffered tax at any previous stage. The assessing authority assessed the dealers on the turnover involved relating to the gingelly seeds under section 7-A of the Tamil Nadu General Tax Act, 1959. The assessing authority had invoked the provisions of section 16 of the Act to bring the escaped turnover to assessment and passed the order. Apart from the respondents-assessees, the cases of a number of other assessees also were similarly treated by the assessing authority. These assessees as well as the assessees in some other cases preferred appeals before the appellate authority, viz., the Appellate Assistant Commissioner. The appellate authority dealt with fourteen appeals by a common order dated 28th August, 1980. The pleas raised by the assessees before the appellate authority failed and the appeals were dismissed. For the limited purpose with which we are concerned in these revision cases, it is not necessary for us to deal with the pleas which were raised before the appellate authority by the assessees. The dismissal of the appeals by the common order by the appellate authority led the assessees including the respondents in the prescient four revision cases to file further appeals to the Tamil Nadu Sales Tax Appellate Tribunal. Before the Tribunal, the case of the assessees was that in view of G.O.Ms. No. 1089 dated 29th June, 1977, the assessees were entitled to the waiver of tax liability for the period from 27th November, 1969 to 14th July, 1975. Before the Tribunal, the case of the assessees was that in view of G.O.Ms. No. 1089 dated 29th June, 1977, the assessees were entitled to the waiver of tax liability for the period from 27th November, 1969 to 14th July, 1975. The Tribunal found on principle that the benefit of G.O.Ms. No. 1089 dated 29th June, 1977 would be available to the assessees, subject, however, to the assessees satisfying the conditions contained in the said Government Order, and since no investigation had been done by the assessing authority with regard to the facts whether or not the obligations contained in G.O.Ms. No. 1089 had been fulfilled by the assessees, the matter was remanded to the assessing authority for fresh disposal. It is as against this order of the Tribunal, the Revenue has come up in revision before this Court. 3. G.O.Ms. No. 1089 dated 29th June, 1977 came to be issued after the judgment of the Supreme Court reported in State of Tamil Nadu v. Kandaswami 1975 (4) CTR 197, 1975 AIR(SC) 1871, 1975 (36) STC 191, 1975 (4) SCC 745 , 1976 (1) SCR 38 , 1975 UJ 521 , 1975 TaxLR 1935, 1975 SCC(Tax) 402. It appears that section 7-A of the Tamil Nadu General Sales Tax Act, 1959, was introduced with effect from 27th November, 1969 by Tamil Nadu Act 2 of 1970. The vires of the section was questioned in the High Court and this Court by the judgment reported in M. K. Kandaswami v. State of Tamil Nadu 1971 (28) STC 227 sustained the challenge and declared section 7-A of the Act to be ultra vires. On appeal by the State, the Supreme Court by its judgment dated 15th July, 1975 reported in State of Tamil Nadu v. Kandaswami 1975 (4) CTR 197, 1975 AIR(SC) 1871, 1975 (36) STC 191, 1975 (4) SCC 745 , 1976 (1) SCR 38 , 1975 UJ 521 , 1975 TaxLR 1935, 1975 SCC(Tax) 402 set aside the judgment of the High Court and held section 7-A to be intra vires. The traders in the interregnum between 27th November, 1969 when section 7-A of the Act was brought into the statute book for the first time and 15th July, 1975 when the judgment was delivered by the Supreme Court, in certain cases, had not collected any amount by way of tax or purporting to be tax, and therefore they made representations to the Government. Those representations were examined by the Government in consultation with the Board of Revenue, Commercial Taxes, Madras. The consultation by the Government with the Board of Revenue ultimately led to the passing of G.O.Ms. No. 1089 dated 29th June, 1977. By the said Government order it was directed that the assessments from 1970-71 be kept alive by the Board of Revenue pending final decision of the Government. The Board of Revenue made certain recommendations in the interest of the welfare of the traders and cordial relationship with them which were accepted by the Government. They are as follows : (1) That the past cases involving transactions liable to tax under section 7A for the period from 27th November, 1969 to 14th July, 1975 where final assessments have been made and no tax under section 7-A has been levied need not be reopened;(2) That no proceedings need be initiated for orders passed levying tax under section 7-A on transactions relating to the period from 27th November, 1969 to 14th July, 1975 where final assessments involving section 7-A are kept pending; and (3) That waiver may be granted for the period from 27th November, 1969 to 14th July, 1975 only in cases where the dealers have not collected any amount by way of tax or purporting to be tax or deposit or contingent liability or who have not made any provisions in the balance sheet to meet tax liability. "4. Before the Tribunal, the assessees contended that they were entitled to the benefit contained in clause (3) of the recommendation, subject to the conditions and stipulation contained in G.O.Ms. No. 1089 supra. In the absence of any investigation into the factual aspects which would have entitled the assessees to the benefit of the waiver, the Tribunal rightly found that the matters required to be remanded to the assessing authority for fresh disposal. Undoubtedly, G.O.Ms. No. 1089 supra. In the absence of any investigation into the factual aspects which would have entitled the assessees to the benefit of the waiver, the Tribunal rightly found that the matters required to be remanded to the assessing authority for fresh disposal. Undoubtedly, G.O.Ms. No. 1089 contained certain obligations which are to be fulfilled by an assessee in order to take advantage of clause (3) supra of the said Government Order. It is not the mere ipse dixit of an assessee that he is entitled to the benefit of that order which will entitle him to take advantage of the Government Order. The matters require a proper and thorough investigation in order to ascertain whether the assessments made under section 16 of the Act by the assessing authority come within the purview of G.O.Ms. No. 1089 dated 29th June, 1977. The Tribunal, therefore, rightly remanded the matters to the assessing authority for fresh disposal and we have not been persuaded to find any fault with the order of the Tribunal in the peculiar facts and circumstances of these cases. 5. The decision of this Court reported in Deputy Commissioner of Commercial Taxes v. Gnanambal 1980 (46) STC 302 relied on by the learned Government Advocate (Taxes), is of no avail. The Division Bench of this Court in that case was not called upon to consider whether the benefit of waiver can be granted under G.O.Ms. No. 1089 to the assessee who fulfilled the conditions and obligations stipulated in that Government Order. The decision in the Gnanambal's case (supra) proceeded on an entirely different facts situation. In that case, a specific order had been passed by the Government exempting the purchase of groundnut kernel by the owners of country oil chekku from liability to tax. The Tribunal sought to extend that exemption by invoking the principle of helping a class of under-privileged and economically backward section of the society even with regard to the purchases of gingelly seeds. The Division Bench on these facts rightly found as follows : It is no part of the duty of the Tribunal to go into any basic theory of public welfare or to find out what the intention behind the order issued by the Government was, nor to extend the scope of the Government Order to any other matters, which are not expressly governed by the language of the Government Order. If any such indulgence is to be resorted to by a statutory body like the Tribunal, the ultimate result will be one of arbitrariness depending upon the whims and fancies of the Tribunal or the economic predilections of the Tribunal, for which there can be no scope in the scheme of our legal system. Under these circumstances, we have no hesitation whatever in holding that the Tribunal went beyond the scope of its powers and, as a matter of fact, unreasonably and unwarrantedly extended the applicability of the Government Order in question to a case to which the terms of the Government Order, neither expressly nor by implication, applied." The above judgment is clearly distinguishable and has no application to the facts and circumstances of the present cases. 6. Thus for what we have said above, we find no merit in these tax revision cases and the same are dismissed. No costs.