Revisional jurisdiction over compliance orders fails where the underlying appellate direction is final and time-barred.

A subordinate order passed in obedience to a final appellate direction cannot be independently revised when the appellate order has already attained finality and the limitation period for revising that order has expired. The revisional authority's power extends to the appellate order itself, but any challenge must be directed to that operative order rather than to the ministerial or consequential order implementing it. A retrospective amendment may affect the underlying tax entitlement, but any illegality attributable to the amendment attaches, if at all, to the final appellate order and not to the compliance order. On that basis, revision against the subordinate order was held to be without jurisdiction.

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Issues: Whether the Deputy Commissioner could initiate revision proceedings against the Commercial Tax Officer's order when the underlying appellate order of the Assistant Commissioner had become final and the period of limitation for revising that order had expired, notwithstanding the retrospective amendment to the sales tax law.

Analysis: The order of the Commercial Tax Officer was passed in obedience to the directions of the Assistant Commissioner in appeal. The revisional power under the State Act could be exercised over the Assistant Commissioner's order as well as the Commercial Tax Officer's order, but the later order could not be revised independently while the appellate order directing it remained unchallenged. The appellate order had become final because the period of four years for revision had expired. Although the retrospective amendment might have affected the admissibility of the refund, any illegality would attach, if at all, to the appellate order and not to the ministerial order passed in compliance with it.

Conclusion: The Deputy Commissioner had no jurisdiction to initiate revision proceedings against the Commercial Tax Officer's order.

Final Conclusion: The writ petition succeeded and the revision notice was quashed, with consequential restraint against further revision proceedings on the disputed turnover.

Ratio Decidendi: An order passed by a subordinate authority in compliance with a final appellate direction cannot be independently revised when the appellate order has become final and is no longer within limitation for revision.

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