Revision notice jurisdiction upheld where no final revisional order existed and limitation was still satisfied.

Section 20 of the Andhra Pradesh General Sales Tax Act, 1957 permits the revisional authority to examine a subordinate order and initiate revision if it is prejudicial to revenue. Where an earlier show cause notice had not resulted in a final revisional order, the revision process had not attained finality, so there was no legal bar to issuing a second notice on another item in the same appellate order, provided limitation was still satisfied. Authorities cited by the petitioner were distinguished because they concerned completed revisions or different limitation contexts. The second show cause notice was therefore within jurisdiction and the challenge failed.

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Issues: Whether the second show cause notice proposing revision of the appellate order on an additional item, after an earlier show cause notice had been issued but no final revisional order had been passed, was without jurisdiction.

Analysis: Section 20 of the Andhra Pradesh General Sales Tax Act, 1957 empowers the revisional authority to call for and examine the record of any subordinate order, and to initiate proceedings to revise, modify or set aside that order if it is prejudicial to the interests of revenue. The earlier notice had not culminated in any final revisional order, and therefore the revision proceedings had not attained finality. In the absence of a completed revision, there was no legal bar to initiating proceedings in respect of another item in the same appellate order, provided the action was within the prescribed period of limitation. The authorities relied on by the petitioner were distinguished on the ground that they involved a completed revision or a different limitation context.

Conclusion: The second show cause notice was held to be within jurisdiction and the challenge to it failed.

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