Summarize the following court judgment. Civil Appeal No. 532(NT) of 1989. From the Judgment and Order dated 4.2. 1987 of the Allahabad High Court in S.T.R. No. 298 of 1986. AND Civil Appeal No. 533 (NT) of 1989. From the Judgment and Order dated 26.3. 1987 of the Allahabad High Court in Sales Tax Revision No. 454 of 1986. S.C. Manchanda	 R.S. Rana and Ashok K. Srivastava for the Appellant. R.C. Mishra and Dr. Meera Aggarwal for the Respondent in C.A. No. 532 of 1989. Raja Ram Aggarwal	 Vijay Hansaria and Sunil K. Jain for the Respondent in C.A. No. 533 of 1989. The Judgment of the Court was delivered by SABYASACHI MUKHARJI	 J. Special leave granted and these appeals are disposed of by the judgment herein. These appeals are from the judgments and orders of the High Court of Allahabad dated 4th February	 1987 and March 26	 1987 respectively. These involve a common question. The facts of the appeal arising out of Special Leave Petition No. 1293 of 1988 and the facts of the appeal arising out of Special Leave Petition No. 1296 of 1988 are similar. In order to appreciate the contentions raised herein	 it would be appropriate to deal with the facts of the appeal arising out of Special Leave Petition No. 1293 of 1988. The assessee is engaged in repairing and refilling of cotton bowl on the shafts which are used as part of calendering machine in the textile industry. The cotton bowl is a shaft made of steel on which a thick layer of cotton is pasted and 425 affixed. It is used in the textile finishing industries as an essential part of calendering machine. In the course of its use the cotton pasted on the shaft loses its thickness and shape and after some time it requires repairing and refilling. The assessee in this case moved an application under section 35 of the U.P. Sales Tax Act	 1948 (hereinaf ter called 'the Act '). It may be mentioned that Section 35 was added by the U.P. Sales Tax (Amendment and Validation) Act No. 23 of 1976. Section 35 of the said Act has been amended by Section 31 of the U.P. Act 12 of 1979. Section 35 provides for determination of disputed ques tions by moving an application before the Commissioner of Sales Tax. The relevant part of the said section as it stood at the relevant time was as follows: "35. Determination of disputed questions (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	 therefore; 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. 426 (2) The Commissioner of Sales Tax shall	 after giving the applicant an opportunity of being heard	 decide	 as he deems fit	 the question so arising: 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 Author ity	 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) XXX XXX XXX. " The question that arises in these appeals before us is the true interpretation of sub section (5) of section 35 of the Act	 namely	 whether a revision shall lie to the High Court from the decision of the Commissioner under section 35 of the Act which has been the subjectmatter of an appeal before the Tribunal. The respondent dealer moved an applica tion under section 35 of the Act and the decision was ren dered in terms of the said section. The decision	 inter alia	 included the questions whether the job of repairing and refilling of cotton bowl and the process involved there in amounted to "manufacture" or "sale" within the meaning of the Act. The Commissioner of Sales Tax by his order dated 10th June	 1985 decided both the questions against the assessee. Aggrieved thereby the assessee had preferred an appeal before the Sales Tax Tribunal. The Tribunal by its order dated 14th November	 1985 allowed the appeal in part. The Tribunal held that the process of repairing and refill ing of cotton bowls of the customers did not amount to "manufacture" as defined under section 2(e i) of the Act. It further held that such an activity of the assessee amounted to "sale" as defined under section 2(h) of the Act as amend ed by the U.P. Sales Tax Amendment and Validation Act	 1985.It is against this decision of the Sales Tax Tribunal that the Commissioner of Sales Tax had preferred revision to the High Court. The High Court went into the question whether further revision lay to the High Court. The High Court	 noticed of the terms of section 35 noted hereinbefore which provided by sub section 5 of section 35 that a decision given by the Commissioner of Sales Tax under that section	 subject to an appeal to the Tribunal	 shah be final. (Emphasis supplied) The High Court examined the question whether further revi sion lay and answered it in the negative. Therefore	 we were concerned in these appeals with the question whether at the relevant time in terms of section 35 of the Act any further revision lay to the High Court from the decision of the Commissioner which has been the subject matter of appeal before the Tribunal. The High Court came to the conclusion that having regard to the scheme of the provisions and the amendment made by the U.P. Act 12 of 1979 and in view of the decision of the Division Bench of the High Court in Indo Lube Refineries vs Sales Tax Officer	 Sector I	 Gorakhpur	 [1987] 66 STC 145 no further revision lay to the High Court from the order of the Tribunal. In that view of the matter	 the High Court dismissed the revision. Aggrieved thereby	 the Commissioner has come up in appeal before this Court in these two appeals. Shri Manchanda for the appellants and Shri Raja Ram Agarwal for the respondents both submitted that the judgment under appeal is not correct though for different reasons. It is necessary to refer to the scheme of the Act and the amendments from time to time effected therein. Broadly speaking	 the assessment is made by the Sales Tax Officer in terms of section 3 and other allied sections. Section 9 of the Act deals with appeals and provides that any dealer or other person aggrieved by the order made by the Assessing Authority other than an order mentioned in section 10 A	 may	 within 30 days from the date of the service of the copy of the order or appeal to such authority	 as may be pre scribed	 request the appellate authority in writing for summary disposal of his appeal. The other consequential provisions of law need not at the present moment be examined in detail. Section 10 provides for Sales Tax Tribunal. The section was substituted at first by Act 12 of 1979 and thereafter by Act 22 of 1984. After the substitution by the Act 12 of 1979 the Act has provided that there shall be a Sales Tax Tribunal consisting of a President and such other members as the State Government may from time to time deem it necessary to appoint from amongst persons who have been	 or who are qualified to be judges of the High Court and persons who hold or have held a post not below the rank of Deputy Commissioner of Sales Tax provided that when the 428 Tribunal consisted of one or more persons who have been judges of a High Court then he or one of them should be appointed the President. Sub section (5) of Section 10 authorises the Tribunal	 as the case may be	 to confirm	 cancel or vary such order. Sub section (2) of Section 10 stipulates that any person aggrieved by an order passed by an appellate authority under section 9 or by the revising authority under section 10 B or by a decision given by the Commissioner of Sales Tax under section 35 may	 within six months from the date of service of the copy of such order or decision on him	 prefer an appeal to the Tribunal. Sub section 10(a) of Section 10 provides that an appeal against the order of the Appellate Authority under section 9 shall be heard and disposed of	 inter alia	 (i) by a bench of one member	 whether such order is passed by an Assistant Commis sioner (Judicial)	 the amount of the tax	 fee or penalty in dispute does not exceed five thousand rupees; and (ii) by a bench of two members	 in any other case. An appeal against the order passed under section 10 B should be heard and disposed of by a bench of two members. An appeal against an order passed under section 35 shall be heard and disposed of by a bench of three members. The President has the power to direct an appeal to be heard and decided by a larger bench and transfer an appeal from one bench to another. There was a subsequent amendment by section 10 of the U.P. Act 22 of 1984. Section 10 as it stands after amendment by Act 22 of 1984 is as follows: "10. Sales Tax Tribunal (1) There shall be a Sales Tax Tribunal consisting of such members	 including a President	 as the State Government may	 from time to time	 deem it necessary to appoint from amongst (a) the persons who are qualified to be Judges of the High Court; and (b) the persons belonging to the Uttar Pradesh Sales Tax Service who hold or have held a post not below the rank of Deputy Commissioner of Sales Tax: Provided that: (i) where the Tribunal consists of one or more persons who is or are members of the Uttar Pradesh Higher Judicial Service	 then he or the senior most amongst them shall be appointed President; 429 (ii) no person shall be appointed from amongst advo cates unless he has paid income tax on income from such profession (exclusive of all other incomes) in each of the five consecutive years preceding such appointment. (1 A) The State Government may prescribe such other qualifi cations or conditions for the appointment of the President and other members of the Tribunal as it may deem fit. (1 B) The provisions of Rule 56 of the Uttar Pradesh Funda mental Rules shall continue to apply to every member of the Tribunal including the President	 whether appointed before or after the commencement of the Uttar Pradesh Sales Tax (Amendment and Validation) Act	 1983	 as they apply to any other Government servant: Provided that a member of the Tribunal including the President	 appointed before the commence of the Uttar Pradesh Sales Tax (Amendment and Validation) Act	 1983	 may continue as such till he attains the age of sixty years. (2) Any person aggrieved by an order passed by an Appellate Authority under Section 9	 other than an order referred to in sub section (4 A) of that said section	 or by the Revis ing Authority under section 10 B or by the Commissioner of Sales Tax under sub section (3) of section 4 A or by a decision given by the Commissioner of Sales Tax under Sec tion 35 may	 within six months from the date of service of the copy of such order or decision on him	 prefer an appeal to the Tribunal: Provided that where the disputed amount of tax	 fee or penalty does not exceed one thousand rupees	 the appellant may	 at his option	 request the Tribunal in writ ing for summary disposal of his appeal	 whereupon the Tribu nal may decide the appeal accordingly. Explanation For the purpose of this sub section	 the expression 'any person ' in relation to any order passed by an authority other than the Commissioner of Sales Tax	 430 includes the Commissioner of Sales Tax. (2 A) The manner and procedure of summary disposal of appeal shall be such as may be prescribed. (3) Section 5 of the 	 shall apply to appeals or other applications under this section. (4) The Tribunal may at any stage	 after giving the appel lant a reasonable opportunity of being heard	 dismiss the appeal. (5) The Tribunal may	 if it has not already dismissed the appeal under sub section (4)	 after calling for and examin ing the relevant records	 and after giving the parties a reasonable opportunity of being heard or as the case may be	 after following the procedure prescribed under subsection (2 A) (a) confirm	 cancel or vary such order	 or (b) set aside the order and direct the assessing or appellate or revisional authority or the Commissioner of Sales Tax	 as the case may be	 to pass a fresh order after such further inquiry	 if any	 as may be specified	 or (c) order such amount of tax	 fee or penalty or other money as may have been realised in excess of the due amount to be refunded according to the provisions of this Act. Explanation The power to vary an order referred to in clause (a) includes the power to vary the order by reducing or enhancing the amount of assessment or penalty. (6) Where an appeal under this section has been filed	 the Tribunal may	 on the application of the appellant moved within thirty days from the filing of such appeal	 after giving the parties a reasonable opportunity of being heard	 stay the operation of the order appealed against or the recovery of the disputed amount of any tax	 fee or penalty payable	or refund of the amount due	 or proceedings for re assessment	 under the order appealed against till the dis posal of the appeal: 431 Provided that: (i) no application for stay of recovery of any disput ed amount of tax	 fee or penalty shall be entertained unless the applicant has furnished satisfactory proof of the pay ment of not less than one third of such disputed amount in addition to the amount required to be deposited under sub section (1) of Section 9; (ii) the Tribunal may	 or special and adequate reasons to be recorded in writing	 waive or relax the requirement of clause (i) regarding payment of one third of such disputed amount. (8) No order passed under this section for the stay of recovery of tax	 fee or penalty shall remain in force for more than thirty days unless the appellant furnishes ade quate security to the satisfaction of assessing authority concerned for payment of the outstanding amount. (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 (1) 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 10 B shall be heard and disposed of by a bench of two members. (c) An appeal against an order passed under sub section (3) of Section 4 A or a decision given under Section 35	 which shall be filed before the President shall be heard and 432 disposed of by a bench of three members. (d) The President may	 if he so thinks fit (i) direct an appeal to be heard and decided by a larger bench; (ii) transfer an appeal from one bench to another bench. (11) The place of sitting and procedure of	 and the manner of presenting appeals and other documents to the Tribunal shall	 subject to the rules	 be such as the Tribunal may deem fit to adopt. (12) The decision of case heard by a bench shall be in accordance with the opinion of the majority. Where the members are equally divided the President of the Tribunal may (a) if he was not a member of such bench	 give his own opinion or refer the case for the opinion of another member	 whereupon the case shall be decided in accordance with such opinions	 or (b) from a larger bench. " The section has been set out in extend in order to appreciate the contentions raised. As will be apparent from the aforesaid sub section 10(c) that an appeal against an order passed or a decision given under section 35 shall be filed before the President and shall be heard and disposed of by a bench of three members. So far as revision is concerned	 this was the subject matter of section 11 of the Act. The Sales Tax Act of 1948 under went an amendment in 1984 so far as revision is concerned and as it stands today and so far as it is material for the present purpose	 is as follows: "11. Revision by High Court in special cases (1) Any person aggrieved by an order made under subsection (4) or sub section (5) of section 10	 other than an order under sub section (2) of that section summarily dis 433 posing of the appeal	 or by an order passed under Section 22 by the Tribunal may	 within ninety days from the date of service of such order	 apply to the High Court for revision of such order on the ground that the case involves any question of law: Provided that	 where such order was served on the person concerned at any time before the date of commencement of this section	 as substituted by the Uttar Pradesh Taxa tion Laws (Amendment and Validation) Act	 1978 (hereinafter in this section referred to as the said date)	 and the period of one hundred and twenty days for making the appli cation as referred to in this sub section	 as it existed before the said date	 had not expired on the said date the person aggrieved may apply for revision within sixty days from the said date. " The other sub sections are not relevant for the present purpose. Section 10 A deals with orders against which no appeal or revision lies and Section 10 B stands for revision by the Commissioner of Sales Tax. Section 11	 as mentioned herein before	 stands for revision by the High Court and has been amended from time to time. In the aforesaid background the question posed in these appeals will have to be examined in the light of the deci sion of the High Court. The High Court in its judgment under appeal after analysing the provisions of Section 35 observed that the Commissioner entered into the determination of the disputed questions. Sub clause (2) of Section 35 of the Act	 according to the High Court	 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 the decision given by the Commissioner of Sales Tax shall sub ject to an appeal to the Tribunal	 be final. The High Court while examining the section noticed that when an appeal against the order passed under Section 35 of the Act is before the Tribunal	 the appeal is to be heard and disposed of by a bench of three members	 although in regard to other appeals before the Tribunal these can be disposed of even by a single member or by a bench consisting of two members. The High Court noted that under subclause (5) of section 35 of the Act prior to its amendment brought out by U.P. Act No. 12 of 1979	 an appeal used to lie to the High Court against the order of the Commissioner of the Sales Tax. By the 434 aforesaid amendment brought out by U.P. Act No. 12 of 1979 under clause (5) of section 35 the words "High Court" have been deleted and substituted by the word "Tribunal". The learned Judge of the High Court observed that an appeal before the Tribunal was specially treated by the legislature and it was enjoined that it should be disposed of by a bench of not less than three members. The learned Judge noted that the Division Bench of the High Court in the case of Indo Lube Refineries vs Sales Tax Officer	 Sector l	 Gorakhpur	 [1987] 66 STC 145 had taken the view that an order passed by the Commissioner under Section 35 of the Act was an adminis trative order and in so doing he did not act as a Tribunal. In this connection reference may be made to the Division Bench decision of the High Court of Allahabad in Indo Lube Refineries (supra). There the petitioner filed a writ peti tion contending that as the order of the Commissioner of Sales Tax had become final under sub section (5) of section 35 of the U.P. Sales Tax Act	 1948	 it was binding on the Revenue as well as the petitioner and it was open to the Sales Tax Officer who was inferior in hierarchy to ignore the order of the Commissioner in passing the assessment order. Dismissing the petition	 it was held by the High Court that the Sales Tax Act had made a clear distinction between judicial proceedings which had to be conducted and concluded in accordance with sections 7	 9	 10	 10 B	 21 and 35 and the High Court noted that the proceedings under sections 7 to 10 B were of different character than the one contemplated under section 35	 and it excluded a proceeding pending before a court or before an assessing authority under section 7 or section 21. It was a type of miscellane ous jurisdiction	 it was held	 to be exercised only in given circumstances or situations. In respect of proceedings under section 7	 which will take within itself an appeal and revision	 the legislature had not made the Commissioner a final arbiter. The Sales Tax Officers or the assessing authority while determining the turnover with a view to assess tax liability acts as a tribunal. Likewise	 the appellant authority under section 9 and the Tribunal under section 10 of the Act are tribunals. The Commissioner did not act as a tribunal while dealing with an application under section 35. The nature of his jurisdiction is adminis trative according to the High Court. The legislature	 ac cording to the High Court	 has used the language "otherwise than in a proceeding pending before a court or before an assessing authority under section 7 or 21" deliberately with a view to maintain and preserve the sanctity of the judicial proceedings under the Act. The word "final" used in sub section (5) of section 35 is only with regard to the pro ceedings contemplated by that section and the order of the Commissioner 435 would be final. But this will not bar the other authorities under the Act from deciding the controversy before it on its own by looking to the evidence and considering the question of law which comes before it. Therefore	 the High Court rejected the submission that the order of the Commissioner of Sales Tax is binding in the assessment proceedings and those proceedings have to be decided in accordance with the same. It is difficult to accept the position that under sec tion 35 which empowers the Commissioner to determine disput ed questions and the Commissioner under sub section (2) after giving the parties opportunity of being heard	 decides a question	 his order can be called to be an administrative order. In our opinion	 the very language of the section which enjoins a decision by the Commissioner envisages that the decision is quasi judicial or judicial and cannot be characterised as administrative. Whether that decision will be binding on other party and what will be the effect of the decision of the Commissioner of Sales Tax in pending assess ment proceedings is another matter and we are not concerned in these appeals with that question. We are concerned with the question whether on the language of the section a revi sion is entertainable from the decision of the Commissioner which has been subjected to an appeal to the Tribunal. In our opinion	 in view of the language used specifically in the absence of a provision that such a revision will be maintainable	 such revision will not be. Sub section (5) of section 35 after the amendment states that the decision of the Commissioner of Sales Tax under this section shall	 subject to an appeal to the Tribunal	 be final. In view of the language of that section	 in our opinion	 it cannot contemplated a further revision to the High Court against a decision of the Tribunal. In Kydd vs Watch Committee of City of Liverpool	 	 331 32	 Lord Lorebum	 L.C.	 construing the provisions of section 11 of the Police Act	 1890 of England which provided an appeal to quarter sessions as to the amount of a constable 's pension	 and also stipu lated that the court shall make an order which shall be just and final	 observed: "Where it says	 speaking of such an order	 that it is to be final	 I think it means there is to be an end of the busi ness at quarter sessions . . " The Judicial Committee in Maung Ba Thaw vs Ma Pin	 [1933 34] 61 LR Indian Appeals 158 while dealing with the Provincial Insolvency 436 Act observed that when a fight of appeal was given to any of the ordinary courts of the country	 the procedure	 orders and decrees of that court would be governed by the ordinary rules of the Civil Procedure Code and therefore an appeal to Privy Council was maintainable by the decision of the High Court. Here in the instant case the right of appeal has been given under the Act not to any ordinary court of the country under the Code of Civil Procedure but to the courts enumer ated under the Sales Tax Act and the revision is contemplat ed under the provisions of the Sales Tax Act. 'Final ' in the section means that it is final and under the Act subject to the limited procedure contemplated under the Act. The inten tion of the legislature	 in our opinion	 in the amended scheme of the Act is clear and manifest and meaningful and the scheme of the Act is to regulate the determination of the question as to the assessability and liability and questions in connection thereto. The observations of Lord Lorebum	 L.C. were referred to in South Asia Industries Pvt. Ltd. vs S.B. Sarup Singh	 	 where this Court observed at page 766 of the report that the expression "final" prima facie meant that an order passed on appeal under the Act was conclusive and no further appeal lay. A right to revision under the Act is a right given by the Act. In this connection	 observations in M/s. Jetha Bai and Sons	 Jew and others vs M/s. Sunderdas Rathenai and others	 may be relied on. We have noted that section 11 of the Act after the amendment stipulated that any person being aggrieved by an order made under sub section (4) or sub section (5) of Section 10	 other than an order under sub section (2) of that section summarily disposing of the appeal	 or by an order passed under Section 22 by the Tribunal	 may apply for revision. Where an appeal is not disposed of summarily but by a decision	 as in this case	 and where the appeal is contemplated in such a situation	 to be heard by a bench of three Judges	 in our opinion	 if any further revision would have laid from the decision of the Tribunal then such deci sion of the Commissioner would not have been made final by sub section (5) of Section 35. It may be mentioned that the Tribunal after exhaustively considering the contentions of the case allowed the appeal in part and the order of the Commissioner of Sales Tax was modified by holding that the process of repairing and refilling of the cotton bowls of the customers did not amount to "manufacture" as defined in Section 2(e 1) of the Act	 as amended by the U.P. Sales Tax (Amendment and Validation) Act	 1985 with effect from 2nd February	 1985. In the scheme of the Act	 in our opinion	 it was enjoined that such an appeal is to be heard by a bench of three judges. 437 Where it was provided that the decision of the Commissioner would be final subject to an appeal to the Tribunal	 in our opinion	 it would be incorrect to contemplate that in such a situation a further revision under Section 17 lay to the High Court. Revision to the High Court in special cases under Section 11 is contemplated on the ground that the case involved a question of law. It may be mentioned that the High Court had mentioned that under sub clause (5) of sec tion 35 of the Act prior to its amendment that an appeal used to lie to the High Court against an order of the Com missioner of Sales Tax. By the aforesaid amendment brought forward by the U.P. Act 12 of 1979 under clause (5) of Section 35 the words "High Court" have been deleted and substituted by the word "Tribunal". It appears that the High Court was right	 therefore	 in holding that an appeal to the Tribunal against an order of the Commissioner lies. So far as the appeal before the Tribunal against the order passed under section 35 is concerned	 special treatment has been provided for by the legislature. The Tribunal has come in place of the High Court in hearing the appeal. In such a situation to contemplate when the language of the section envisages that the order of the Commissioner would be final	 subject to an appeal to the Tribunal that a further revision lay to the High Court would be unwarranted. As mentioned hereinbefore	 we have to find out the intention of the Legislature in such a situation. The intention of the Legis lature is a slippery phrase as observed in Aron Salomon vs A. Salomon and Company Ltd.	 ; 	 38 see also observations in Lord Howard De Walden vs Inland Revenue Commissioners	 [1948] All England Reports page 825. In such cases it is better to find out the intention of the legisla ture from the words used by the natural meaning of the words and spirit and reason of the law. See Cross on Statutory Interpretation	 Second Edition	 page 21. Having regard to the scheme manifested from the amend ment	 that is to say	 to make the Commissioner 's decision final	 subject to an appeal to the Tribunal where the Tribu nal is enjoined to hear such an appeal by a bench of three members and where revision is provided only in special cases	 in our opinion	 it would be improper to interpret the spirit and reason of that law in such a way as to enjoin that a further revision lay to the High Court under section 11 of the Act. In our opinion	 therefore	 the High Court was right that no further revision in such a situation lies to the High Court. This	 however	 does not eliminate the cor rection by the High Court. In an appropriate case by exer cise of a writ of certiora under Article 226 of the Consti tution it exercises superintendence over all courts and tribunals throughout the 438 territory. See in this connection Re Gilmore 's Application	 [1957] 1 All England Reports 796. We are not concerned with that situation in these appeals. In that view of the matter it appears to us that the High Court is right in so far as it held that no revision lay to the High Court. These appeals	 therefore	 fail and are dismissed. Par ties will pay and bear their own costs. N.V.K. Appeals dismissed.

The assessee respondent in the appeals was engaged in the repairing and refilling of cotton bowls on the shafts which are used as part of calendering machine in the textile industry. The cotton bowl is a shaft made of steel on which a thick layer of cotton is pasted and 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. The assessee moved an application under section 35 of the U.P. Sales Tax Act	 1948 and the decision inter alia included the question whether the job of repairing and refilling of cotton bowl and the process involved therein amounted to "manufacture" or "sale" within the meaning of the Act. The Commissioner of Sales Tax decided both these ques tions against the assessee	 and the assessee preferred an appeal before the 422 Sales Tax Tribunal. The Tribunal allowed the appeal in part. It held that the process of repairing and refilling of cotton bowl of the customers did not amount to "manufacture" as defined under section 2(e i) of the Act. It further held that such an activity of the assessee amounted to "sale" as defined under section 2(h) of the Act as amended by the U.P. Sales Tax Amendment and Validation Act	 1985. The:Commissioner of Sales Tax preferred a revision to the High Court which went into the question whether a fur ther revision lay to the High Court. It came to the conclu sion having regard to the scheme of the provisions contained in section 35 and the amendment made by the U.P. Act 12 of 1979	 and the earlier Division Bench decision of the High Court in Indo Lube Refineries vs Sales Tax Officer	 [1987] 66 S.T.C. 145 (All) that no further revision lay to the High Court from the order of the Tribunal. The High Court accord ingly dismissed the revision. The Commissioner appealed by special leave to this Court. On the question: whether a revision shall lie to the High Court from the decision of the Commissioner under section 35 of the U.P. Sales Tax Act which has been the subject matter of an appeal before the Tribunal. Dismissing the Appeals	 the Court	 HELD: 1. The very language of section 35 of the U.P. Sales Tax Act	 1948 which enjoins a decision by the Commis sioner envisages that the decision is quasi judicial or judicial and cannot be characterised as administrative. The question is whether on the language of the section a revi sion is entertainable from the decision of the Commissioner which has been subjected to an appeal to the Tribunal. In view of the language used specifically in the absence of a provision that such a revision will be maintainable such revision will not be. [435C E] 2. Sub section (5) of section 35 after the amendment states that the decision of the Commissioner of Sales Tax under this section shall	 subject to an appeal to the Tribu nal	 be final. In view of the language of that section	 it cannot contemplate a further revision to the High Court against a decision of the Tribunal. [435E F] Indo Lube Refineries vs Sales Tax Officer Sector l. Gorakhpur	 [1987] 66 STC 145	 approved. 423 3. In the instant case	 the right of appeal has been given under the Act not to any ordinary Court of the country under the Code of Civil Procedure but to the courts enumer ated under the Sales Tax Act	 and the revision is contem plated under the provisions of the Sales Tax Act. [436B] 4. "Final" in section 35 means that it is final and under the Act subject to the limited procedure contemplated under the Act. The expression 'final ' prima facie means that an order passed under the Act was conclusive and no further appeal lay. A right to revision under the Act is a right given by the Act. [436C D] Kydd vs Vatch Committee of City of Liverpool	 	 331 32; Maung Ba Thaw vs Ma Pin	 [1933 34] 61 LR Indian Appeals 158; South Asia Industries Pvt. Ltd. vs S.B. Sarup Singh	 and M/s. Jetha Bai and Sons Jew and others vs M/s. Sunderdas Ratheni and others; 	 	 referred to. Revision to the High Court in special cases under section 11 is contemplated on the ground that the case involved a question of law. [437B] 6. Having regard to the scheme of the U.P. Sales Tax Act	 1948 manifested from the amendment	 to make the Commis sioner 's decision final	 subject to an appeal to the Tribu nal where the Tribunal is enjoined to hear such as appeal by a Bench of three members and where revision is provided only in special cases	 it would be improper to interpret the spirit and reason of that law in such a way as to enjoin that a further revision lay to the High Court under section 11 of the Act. The High Court was	 therefore	 right that no further revision in such a situation would lie to the High Court. [437F G] 7. This	 however	 does not eliminate correction by the High Court. In an appropriate case by exercise of a writ of certioraris under Article 226 of the Constitution it exer cises superintendence over all Courts and Tribunals through out the territory. [437G H] Re Gilmore 's Application	 [1957] 1 All England Reports 796	 referred to. The intention of the legislature is a slippery phrase. It is better to find out the intention of the legis lature from the words used by the natural meaning of the words and the spirit and reason of the law. [437E] 424 Aron Salomon vs A. Salomon and Company Ltd.	 ; 	38; Lord Howard De Walden vs Inland Revenue Commis sioners	[1948] 2 All England Reports page 825. referred to. Cross Statutory Interpretation (Second Edn.) p. 21. referred to.